Dear Mark,

I would like to introduce you to the Australian Advertising Standards Bureau (ASB). You may not have heard of them but they have made a ruling down here that may cause you some grief, and potentially decrease the number of brand pages on Facebook. Following a recent ruling, the ASB will now hold brands and companies with Facebook profile pages accountable for comments made on their pages by the general public.

In reviewing brewer CUB’s Victoria Bitter brand Facebook page, which allegedly (in a complaint) contained sexist and racist content, references to irresponsible drinking and obscene language in user-submitted comments and imagery, the ASB ruled: “The board considered that the Facebook site of an advertiser is a marketing communication tool over which the advertiser has a reasonable degree of control and could be considered to draw the attention of a segment of the public to a product in a manner calculated to promote or oppose directly or indirectly that product.”

The ASB, in their wisdom, has decided that comments, pictures or any other user-generated content posted and left on a brand’s Facebook page is a form of advertising and therefore is subject to regulation under our Australian advertising codes.

That’s right, Zuck. The ASB reckons a comment from any random visitor on a brand’s Facebook page is now an advertising message – surely this makes you shake your head, as many of us are. What this ruling indicates is that social media is about to change for brands and the Advertising Standards Bureau is happy to make it happen quickly. Unfortunately there’s been little discussion with you or your users. Probably doesn’t make you happy.

The plan down here is to make brands accountable for everything that is posted on their Facebook brand page, which is a dramatic change that will lead to a massive increase in workload (and expense) from a monitoring perspective and to be honest, I think it is something you should address.

We all know your moderation tools include the age restriction feature, pre-moderation of comments, as well as restrictions on the types of posts that can be shared (photos/videos), administrative control over ‘page visibility’ requiring all posts to be approved before they are published to the timeline, and automatic blocking of posts based on offensive language, but brands need greater control over comments posted on their page content.

My suggestion is to have a flagging mechanism built into Facebook that allows users to create a community that identifies any material that is seen to be malicious in its content. This would still allow people to have their say, but also gives other users the power to express their opinion on what should and shouldn’t be kept on a brand page. I know it’s a little bit of work for your company, but I think it will ensure brands are confident that you are supportive of them.

As a ‘fan’ of many brand pages, and a digital strategist who recommends your website as a key part of my strategies, I have never posted obscene or intentionally offensive comments or content, but I know it’s a liability my clients face. What I am asking, Mark, is can I truly recommend Facebook to brands as a realistic part of my digital strategy when I also have to tell the client to hire a social media community manager to monitor messages and content because the current tools are insufficient?

Monitoring is a time-consuming effort and would be possible 24/7 in an ideal world, but not all brands have the staff or financial resources to enable this, so how can we make this automated? That’s where you come in to help us out!

Social media was meant to open the communication channels between people locally and internationally. It was meant to enable real-time communication between brands, organisations, businesses and the public. If this becomes a dangerous and potentially expensive prospect, you risk the value and authenticity that Facebook has always championed.

Rather than meekly accept this ignorant and hasty ASB ruling, show the millions of Facebook users worldwide that they can trust you to promote their freedom of speech in an appropriate manner and come up with some real moderation tools. This will allow me to confidently include you in my strategy packs again. Mark, don’t make me recommend other social media platforms – prove that your fans have a valuable say in how Facebook is designed so that brands and the public can be confident you care.

Hopefully still a fan,

Grant Flannery
Digital strategist
Reactive