Updated Guidelines for Gathering, Moderating and Marketing Reviews

Updated 3/11/22

We’ve discussed the Federal Trade Commission’s role and previous rulings in other blog posts. The FTC recently updated guidelines for businesses, marketers and review management platforms so we thought it would be best to share what we know and what we are doing to help you navigate these guidelines. 

So what are these new FTC guidelines and what is GatherUp doing to adhere? 

In this blog post we will walk through best practices for your online reputation strategy.

How to ask for feedback and reviews

The best practice for asking for reviews is to ask ALL your customers for feedback. If your goal is truly to listen to your customers so that you can create better business outcomes, you need a full scope on the customer experience. Do not be selective about who you ask for a review. And don’t make it more difficult for some customers to leave a review than others.

FTC’s Basic Principles: 

  1. Don’t ask for reviews only from people you think will leave positive ones.
  2. If you offer an incentive to consumers for leaving a review, don’t condition it, explicitly or implicitly, on the review being positive. Even without that condition, offering an incentive to write a review may introduce bias or change the weight and credibility that readers give that review. For these reasons, some platforms have prohibited incentivized reviews altogether or have established mechanisms for labeling them.
  3. Don’t prevent or discourage people from submitting negative reviews.

GatherUp has always been at the forefront of compliance and best practices. We believe “listening is a business superpower.” A business shouldn’t pick and choose which customers to listen to.

Therefore, we encourage an unbiased feedback collection that includes ALL customers. Our Request Modes have been in compliance with Google’s TOS and also with the FTC’s basic principles outlined above. It’s important to give all customers, regardless of their known or unknown feelings, a chance to leave feedback or a review. 

It’s important to remember that GatherUp does not condone incentivizing reviews. In fact, no incentive is the best incentive. If the goal of asking for feedback and reviews is to better understand the overall customer experience you should not be incentivizing reviews. Avoid asking employees and family for positive reviews as that not only violates the FTC’s guidelines, but also skews your business’ reputation.

Publication of feedback and reviews

Perhaps the single most important element of the FTC guidelines is around the publication of reviews. The FTC assessed a fine to online retailer Fashion Nova primarily for withholding negative reviews from its site.

Displaying reviews on your site has many benefits. There is an SEO benefit to showing updated, customer-generated content regarding their experience with a business. There are also social proof benefits. Customers strongly rely on the opinion of others to make purchase decisions. All of this is reliant on the displayed reviews being an accurate representation of the business’ review portfolio. 

The FTC believes in these basic principles:

  1. Publish all genuine reviews and don’t exclude negative ones.
  2. Don’t display reviews in a misleading way. For example, it could be deceptive to feature the positive ones more prominently.
  3. If you display reviews when the reviewer has a material connection to the company offering the product or service — for example, when the reviewer has received compensation or a free product in exchange for their review — that relationship should be clearly and conspicuously disclosed.
  4. Clearly and conspicuously disclose how you collect, process, and display reviews, and how you determine overall ratings, to the extent necessary to avoid misleading consumers.
  5. Have reasonable procedures to identify fake or suspicious reviews after publication. If a consumer or business tells you a review may be fake, investigate and take appropriate action. That may include taking down suspicious or phony reviews, leaving them up with appropriate labels, issuing an alert about them, and addressing the issue with those responsible for it.

As stated earlier, GatherUp has always communicated that best practice is to show all reviews, regardless of star rating. More transparency builds more trust and a trusted reputation is more important than a 5-star rating.

For this reason, we highly recommend current GatherUp customers show all reviews within the Review Widget. You can do so in Step 2 of the Review Widget Settings. Set the 1st and 3rd party reviews to display for “0 stars” and up. Set the Rating Average Calcuation to “Per All Reviews.” If you’re displaying Facebook recommendations, make sure that is set to “Show All.”

Screenshot of GatherUp Review Widget Settings

Our Conversion Pop-up is another highly effective way to display reviews because it builds trust driving higher conversion rates. Much like the Review Widget, our Conversion Pop-up displays reviews on specific pages of your website. 

We have updated default settings for new customers similarly to how we have done so with the Review Widget. The defaults will show all reviews, 0 stars and up. If you are using the Conversion Pop-up make sure you confirm the settings are compliant with the new FTC guidelines. 

All reviews, regardless of star rating, should be shown in the review widget. GatherUp sers still have the ability to remove any inappropriate or spam reviews manually. The guidance for review moderation can be seen in the next section. 

Publishing all reviews is not only the right thing to do, but in some ways, it’s the best way to do business. Most consumers are savvy enough to realize a business will sometimes have unhappy customers who leave a low rating. That makes you an authentic, transparent business. 

In fact the likelihood of purchase peaks at a star rating of 4.0 – 4.7, then decreases as the rating gets closer to 5.0. 

We also strongly encourage businesses who are displaying reviews on their site to include a terms of service that not only outlines how they are collecting reviews, but also why certain reviews would not be eligible for display on the site. You do have a right to not show all reviews. Just make sure the reason is solid and outlined in your TOS. For instance, here is Google’s Content Policy as it relates to reviews.

How to moderate reviews as a business or company

Managing an online reputation encompasses all things related to how you show up online. Many businesses will come to us and ask about removing fake reviews, or reviews from non-customers. Often a business will have to go through the review platform itself, such as Google, to get a review removed. However, when it comes to 1st party reviews, the onus is on the business to moderate the reviews. 

Google recently published an overview of their moderation process. Most businesses don’t have machine-learning capabilities to help in moderating, but this gives you Google’s basic concepts and you can add your own principles.

Here is how the FTC lays out their basic review moderation principles:

  1. Have reasonable processes in place to verify that reviews are genuine and not fake, deceptive, or otherwise manipulated. As technology and threats change, be proactive in modifying and upgrading your processes.
  2. Don’t edit reviews to alter the message. For example, don’t change words to make a negative review sound more positive.
  3. Treat positive and negative reviews equally. Don’t subject negative reviews to greater scrutiny.

Currently, within GatherUp you’re unable to edit reviews entered using GatherUp’s feedback requests. No matter how you’re collecting reviews, either internally or through a reputation management platform, it’s imperative your reviews and feedback are legitimate and unaltered. However, should you find a spam review, or something you need removed, reach out to our support team for help. 

It’s best to have a process in place for verifying reviews. This could include:

  • Matching reviews to customers
  • Spot-checking all reviews, not just negative ones
  • Create notifications for specific keywords that could signal spammers are leaving reviews

We have created a User Guide that provides helpful tips on Review Moderation and creating an Online Review Policy. Businesses should consult with their legal counsel when creating this policy. Best practice would be to display this policy on the same page of your website that hosts your reviews. 

Summary on FTC Guidelines

We will continue to monitor updates or changes to the FTC’s guidelines and basic principles. We believe listening is a business superpower. Businesses should not be selective about who or how they listen, nor should they be selective in what feedback and reviews are being displayed to the public. 

Customer experience is the backbone of every business. Be honest, transparent and ethical. If you follow our guidance and the guidance from the FTC, you will build a better, more successful business. 

For additional information here is a link to the FTC’s Guide for Marketers.



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