Influencer and content creator guidelines

The growth of social media influencers and content creators in recent years marks a shift from traditional media to a ‘creator economy’ driven by social platforms like YouTube, Facebook, Instagram, Snapchat, Pinterest, LinkedIn, TikTok and multicultural media channels.

Social media influencers and content creators can complement traditional communications approaches by reaching niche audience groups and delivering messages through native content formats.

Definitions

Influencers and content creators

An ‘influencer’ or ‘content creator’ is an individual or group of individuals with an established social media audience.

Ambassadors

An ‘ambassador’ is an individual or entity who has a formal agreement with a Victorian Government entity (e.g. a department or agency) to play an advocacy role, to deliver multiple communications deliverables over a period of time.

The following pages outline the steps Victorian Government entities should take when engaging with Influencers or content creators.

Having a clearly defined strategy when engaging with influencers/content creators will minimise any reputational risk for Victorian Government entities.

Before formally engaging an influencer or content creator, government entities should consider the following:

• appropriate internal approval processes for the engagement (i.e. legal, media and governance)
• consultation with your entity’s media team, to ensure they have awareness of the planned engagement
• developing a clear brief for the engagement (establishing clear objectives, audience, message and KPIs)
• assess how the proposed engagement strategy aligns with your entity’s values and ensures political neutrality
• option of hiring a specialist media agency to engage and manage the influencer or content creator.

Always choose an influencer/content creator who discloses their social media partnerships clearly and strives to be inclusive, open and apolitical.

When choosing influencer/content creators:

• verify that the influencer has a legitimate following
• determine whether their audience, brand and values align with those of your department/agency
• determine how the influencer/content creator’s existing content fits with your influencer/content creator strategy.

Victorian Government entities should vet potential influencers/content creators (and ambassadors) thoroughly (or, if you are using the services of a media agency, ensure the agency does this) to ensure they are an appropriate choice for government communications.

The vetting and due diligence process for engaging an influencer or content creator without agency representation should include, but not be limited to, the following:

• Content and reputation vetting: Review the influencer's or content creator's publicly available content from the preceding 6 to 12 months to identify any material that may be controversial, inconsistent with the entity's values, or otherwise present reputational risks.
• Vetting of previous partnerships: Examine prior commercial collaborations and sponsorship arrangements to determine whether they align with your entity's objectives, values and target audience, and to assess the effectiveness and engagement levels of those partnerships. Check for potential conflicts of interest, political affiliations, past criminal activity or reputational risk to the Victorian Government.
• Verification and vetting of audience metrics: Obtain evidence of account performance, such as a screen recording or screenshots from the influencer's analytics dashboard, to verify audience demographics, engagement rates, reach and other relevant performance metrics.

Victorian Government entities must avoid engaging influencers who:

• engage in risky, unhealthy, illegal or undesirable activities (such as smoking, promoting extreme dieting or taking illicit substances)
• post or express views that are racist, sexist, or homophobic
• bully people
• make jokes at the expense of vulnerable or marginalised people
• are associated with organisations or causes that may cause reputational or legal risk
• are (or have been) involved in public controversies or are openly political
• work with brands that conflict with your entity’s values or your campaign’s key message
• refuse to meet requirements to ethically and consistently disclose the nature of the influencer relationship, and other conflicts of interest.

You may choose to add other criteria to vet influencers that are not suitable for your campaign.

Once you have decided to engage with a content creator/influencer, you must ensure there is a written agreement in place between the influencer/content creator and your entity.

Written agreements with influencers/content creators should include:

• clear expectations and deliverables
• agreement on which social media platform(s) will be used
• agreement on how long the Influencer/Content Creator will be engaged with your campaign
• how long the influencer/content creator will carry relevant campaign content on their social media accounts
• clear terms covering what happens if an influencer breaches the contract
• clear terms regarding intellectual property rights, moral rights, and any licenses required by the entity, including whether the influencer is permitted to use campaign content outside of the parameters of the campaign. It is important to seek legal advice on these terms, specific to your agreement
• the appropriate course of action if the influencer incurs reputational damage, as determined by the entity, or engages in conduct or publishes content that may negatively impact the entity’s reputation
• compliance and brand safety measures
• requirements for disclosing the relationship between the influencer and your entity. To avoid misleading consumers, and to comply with Australian Consumer Law, the influencer must explicitly disclose in their posts that the content is a partnership with the entity - e.g. #ad or #paidpartnerships. These disclosure requirements should be written into the contract between the entity and influencer.
• clear terms allowing the entity to review/approve content before it is posted/published by the influencer. The entity will potentially be legally co-responsible for any false or misleading claims published in posts they sponsor.

Consult with your entity’s legal team prior to sending the Influencer the written agreement.

Where influencer or content creator activity forms part of a paid advertising campaign that requires DPC and/or Advertising Approvals Group approval, you must include the following information as part of your campaign submission:

• Objectives and rationale of your influencer/content creator strategy
• Creative concepts/scripts/storyboards, where available
• Role of influencer/s
• Disclosure and accessibility approach
• Media channel mix
• Budget breakdown (fees, production, total cost)

The agreement between the media supplier (OMD) and DPC on engaging with influencers/content creators outlines the various types of influencer partnerships and whether your campaign’s approved media buy (MAMS) budget can be used to cover the cost of influencers.

Consider how many people you want to reach, and how an influencer will achieve this for you, and use these objectives to shape your campaign’s evaluation framework.

The evaluation framework should set clear performance parameters, benchmarks and KPIs for the engagement, which should be included these in the written agreement with the influencer.

Your evaluation framework should include metrics covering:

• Reach
• Impressions
• Engagement
• Brand awareness
• Conversion goals
• Improved audience sentiment

The written agreement should also require real-time performance analysis from the influencer while the campaign is running and reporting of outcomes against campaign metrics as part of the post-campaign reporting.

The below table outlines whether the specific type of influencer/content creator arrangement can be engaged through the government’s media buy (MAMS) contract with its contracted media supplier, OMD.

As part of OMD’s ancillary service offering, OMDCreate can be utilised for creative services. To engage OMDCreate’s services, you will require a separate brief and a dedicated Purchase Order. Unlike paid media (advertising), the MAMS fee does not apply to ancillary work delivered through OMDCreate.