Partnership Policy
Purpose and Scope
Compassion in Caregiving (“we,” “us,” “our”) is committed to transparency and honesty in all of its advertising messages and promotional communications with consumers. One of the most common ways companies promote products and services in social media is by using third-party partners. Like other types of advertising, promotion must be truthful and not misleading. Consumers must understand when a partnership is sponsored by another entity (“brand”).
This Partnership Policy (“Policy”) applies to Compassion in Caregiving’s promotion of a brand or its products or services in digital or non-digital form. The provisions in this Policy are based on legal and regulatory requirements to which Compassion in Caregiving and its employees are subject. Compassion in Caregiving also considers many of the requirements in this Policy to be best practices for engaging in online communities and spaces.
We will never use endorsements or testimonials in our public statements, announcements, advertising media or promotional activities for the psychotherapy services of Compassion in Caregiving. This Policy is specific to our partnerships with brands.
Defining our Partnerships as Covered by This Policy
Our content and conduct in our digital and non-digital partnerships are covered by this Policy if the promotional messages about a brand or its products or services are promoted by us. A product or service is promoted by Compassion in Caregiving if we have a material connection with the brand. A material connection is a connection to us which, if known to consumers, might make consumers question the credibility of the content or materially affect the weight consumers place on the promotional material. For example, Compassion in Caregiving creates a material connection if we do any of the following:
Receive cash or in-kind compensation or remuneration for reviewing a product or service.
Enter into an agreement with an individual or entity to blog or post content.
Pay an individual to blog or post.
Receive money to blog or post about a brand or its services.
Provide discounts, contest entries, or other incentives to an individual on behalf of a brand.
This list is not exhaustive. Check with us for any questions about whether Compassion in Caregiving’s behaviour or actions have created or will create a material connection with a third party.
We Comply with Our Regulatory and Professional Code of Ethics and Standards of Conduct and our Professional Obligations
At Compassion in Caregiving, we take seriously our regulatory obligations and commitments.
We:
Always maintain total and complete independence in any and all decisions regarding the involvement of Compassion in Caregiving, its staff, and engaging in any promotional partnerships whatsoever;
Always maintain total and complete independence in any and all decisions regarding any messaging whatsoever, including when we engage in promotional partnerships;
Always disclose our material connection to any brands in a clear and conspicuous manner;
Ensure that any and all of our claims are substantiated by evidence, including a credible body of social work literature and knowledge;
Are not making unsubstantiated or claims about any brand or its products or services;
Ensure that any and all of our claims are in service of, and of benefit to, our community or audience;
Are not making any improper claims;
Will never ask any community member to like, share, or comment on any of our posts; and are otherwise complying with this Policy and any other guidance we have provided.
With respect to promotional statements or other claims made by us on digital and non-digital platforms about brands or their products or services, we adhere to the following principles:
We only make statements that:
reflect our honest beliefs, opinions, or experiences; and
are transparent about our connection to any brand.
We will not:
Make deceptive or misleading claims to consumers about our experience with a brand or its products or services;
Disclosing a Material Connection Clearly and Conspicuously
When posting about brands or their products or services, Compassion in Caregiving discloses our material connection to a brand clearly and conspicuously. If we have multiple material connections to a brand, the full extent will be disclosed.
This policy does not prescribe specific language to disclose a material connection for each use case, but we communicate the material connection effectively so that consumers:
Can easily find it.
Can easily understand it.
Obtain sufficient information from it to make a judgment about the value and credibility of the promotion.
To ensure a disclosure is clear and conspicuous, appropriate consideration should be given to the limitations and nature of the platform being used. We:
Ensure the disclosure is:
well-placed so it can be easily noticed; and
prominent so it can be easily read.
Avoid burying the disclosure:
in a bio;
below the fold;
in a hyperlink, like a “Legal” or “Disclosure” button; or
among a series of hashtags, other disclosures, or general copy.
Clearly identify a material connection disclosure on images, including on Instagram. The disclosure should be:
easy to notice and read in the time that followers have to look at the image; and
well-contrasted against the image.
In video posts:
place the disclosure both within the video itself and in the description of the video; and display the disclosure long enough for a consumer to be able to read and understand it.
In podcast episodes:
include the disclosure within the podcast episode itself and in the shownotes of the podcast episode; and play the disclosure long enough for a consumer to be able to hear and understand it.
In Instagram posts, disclose a material connection before the “More” button.
· For a livestream, repeat the disclosure as needed to ensure that consumers see it or keep it posted throughout the livestream.
· If the posts are part of an online chat or tweets, or a similar thread, make the disclosure clearly in the first entry into the conversation thread and then add to subsequent entries at entry intervals depending on the media and the length of the thread.
· Disclose the material connection even when just tagging a brand in a photo.
· For a television or radio talk-show appearance, disclose the material connection verbally
when promoting any brand or its products or services.
We avoid encouraging promotions that use features that do not allow for clear and conspicuous disclosures, such as likes, pins, or shares, if the absence of that disclosure is likely to be misleading. A social media platform may have a required tool or feature for paid partnerships.
Though these tools or features must be used to comply with the platform’s rules, they should not be relied on alone to meet Competition Act, R.S.C. 1985, c. C-34, Advertising Standards Canada Canadian Code of Advertising Standards.
What We Provide to Promotional Partners
When we engage with a brand, we agree in writing to:
· Comply with the guidelines set forth in this Policy.
A brand must also provide us with an outline, for us to vet in accordance with this Policy, of:
· Message points, facts sheets, or other similar talking points about the products or services
at issue that do not necessarily prescribe what we should say, but include:
a list of claims about the brand’s product or service that the brand has substantiated;
and
guidance on what we cannot say about the brand’s product or service.
We must also be familiar with the rules and regulations of the College of Social Workers and Social Service Workers (with respect to advertising and endorsements), the Competition Act, and the ASC Code, including:
the Competition Bureau’s Deceptive Marketing Practices Digest – Volume 4;
the Competition Bureau’s Deceptive Marketing Practice Digest – Volume 5;
the Competition Bureau’s influencer marketing guidelines; and
the ASC’s Influencer Marketing Steering Committee Disclosure Guidelines.
Monitoring Our Partnerships
Compassion in Caregiving must regularly monitor and approve our postings of partnered content:
Every partnered campaign or relationship has monitoring responsibilities clearly identified.
We monitor our partnerships for a minimum of three (3) months past the end of our
relationship. For longer campaigns or relationships, it may be necessary to monitor for more than six (6) months.
A Case of Inadvertent Failure to Comply with This Policy
In the event that Compassion in Caregiving inadvertently fails to disclose a material connection or communication of any unsubstantiated claims, Compassion in Caregiving will correct this inadvertence by taking the following steps:
Determine whether a correction is needed and how best to make the correction, if required.
If needed, we will make the correction or post the correction on our post or page directly.
· Determine if it is necessary to:
terminate the relationship with the entity or brand; or
pursue any other legal remedies to which we may be entitled.
All written agreements with promotional partners must give Compassion in Caregiving the right to take any of these corrective measures for non-compliance with this Policy.
Training on This Policy
All staff of Compassion in Caregiving must have knowledge of this Policy.
Compliance with Related Policies
All of our other policies that apply to social media use remain in full force and effect.
Administration of This Policy
Compassion in Caregiving is responsible for the administration of this Policy. All staff of Compassion in Caregiving are responsible for consulting and complying with the most current version of this Policy. If you have any questions regarding this Policy, please contact us at info@compassionincaregiving.com.