Is Your Bank’s Facebook Promotion Legal?
Umpqua Bank is “a surprisingly different community bank,” as it says on its Facebook timeline, a bank where everyone is welcome: “your mom, your kids, your dog.” And the holiday Facebook promotion it’s running to “make our neighborhoods a better place” goes right to the heart of theUmpqua brand.
Umpqua’s “The Joy of Giving” social promotion lets fans play Santa by trying to win money for their favorite charities. The campaign connects the bank with generosity, an important counter-tactic to the sometimes “bad” news in the media about financial institutions. In addition, and perhaps most importantly for a bank that aims to help locally with the needs in each of its markets, the promotion supports organizations identified as deserving by customers in Umpqua Bank communities.
It’s terrific that Umpqua is giving so generously and allowing its fans to have a voice about who receives its donations. Unfortunately, not all good ideas comply with Facebook’s promotion guidelines. By prompting fans to comment as a way of entering their charity to win a prize,Umpqua violates the rules. We doubt, of course, that Facebook would play Scrooge and target this promotion for removal as it has others, but be careful as you plan 2013 promotions.
What’s the #1 best practice for running Facebook promotions? Make sure they’re compliant! Facebook is very specific about what you can and cannot do whenever you have a prize and plan on picking a winner. We decoded Facebook’s guidelines in detail here, but we thought it may be time for a quick refresher:
- DO NOT run a promotion on your wall/timeline. Instead, create an app for your page or host the promotion somewhere else entirely.
- DO use Facebook status updates to direct fans to the location of your promotion.
- DO NOT ask fans to enter or vote by liking, sharing, commenting, posting or checking-in. All of Facebook’s standard features are off-limits when it comes to participating in a promotion.
- DO NOT state that you will select a fan randomly from your likers to win a prize. Fans must enter each promotion purposefully … and without using a Facebook function.
- DO make rules and disclaimers clear, including standard language that your promotion is not associated with Facebook and that you, not Facebook, are collecting information about participants.
- DO NOT contact your winner through Facebook. Grab contact information for participants when they register on the app or external site. (You can post about your winner in a status update, but you cannot use Facebook to notify the winner.)
