A disclosure in a policy page may not accompany an endorsement

Establish the relationship the disclosure needs to explain

Start with the actual arrangement between the business and the endorser. Consult the affiliate agreement, placement approval or other genuine record to identify a commission, payment, employment relationship or other thing of value when present. Do not invent a connection from the existence of a link, and do not assume that a missing contract means no relationship exists. An unresolved arrangement is a question for the business owner responsible for it.

The FTC’s staff Q&A discusses connections that readers would not expect and that would affect how they evaluate an endorsement. That requires comparing the real relationship with the reader-facing presentation. A page that looks independent while its publisher earns from referrals needs that relationship examined. This worksheet records the facts for that assessment; it does not decide the legal status of an unseen arrangement.

Follow the recommendation to the words the visitor sees

Open the authorized page at the actual recommendation and note the device, view and date. Copy the relevant disclosure text into your private review record and describe where it appears. Record whether the visitor sees it with the recommendation, must scroll elsewhere, or must follow a link to a separate policy. A disclosure found through a footer search is not evidence that it accompanied the endorsement as encountered.

The FTC’s affiliate guidance calls for clear and conspicuous disclosure close to the recommendation. Its discussion also explains why a relationship stated on a profile page can be missed by someone who sees only the post. Use that distinction to examine a policy-only disclosure: the policy’s existence answers where information is stored, while this review asks where the audience encounters it.

When the placement includes a platform disclosure label, record its actual words and position along with any publisher-written disclosure. The FTC guidance does not treat use of a platform tool as automatically sufficient; the question remains whether the connection is actually conveyed. Keep different published placements separate because a label present in one view does not establish that it appears in another.

Separate unclear wording from hidden placement

A disclosure can be easy to find but unclear about the relationship, or clear in meaning but located away from the endorsement. Record both dimensions. Does the wording describe the actual connection in terms the reader can understand? Can the reader encounter that explanation with the recommendation? If only one answer is supported, leave the other question open.

Do not copy a supposed safe phrase onto every placement. The relationship, surrounding presentation and audience matter. The FTC Q&A is staff guidance rather than a safe harbor, and the Guides themselves are not law. Where the factual record leaves uncertainty about what must be disclosed or whether a particular presentation is adequate, take that bounded question to qualified counsel.

Keep claim support on a separate track. Disclosing a commission does not substantiate a product claim, and honest enthusiasm does not permit an endorsement to make a claim the advertiser could not lawfully make. For a research-only catalog, a disclosure change must not be used to keep an unsupported use or outcome claim in circulation. Route that wording concern to the claims review as well.

Assign a placement correction and retain the observed result

If the map shows that the connection is explained only elsewhere, ask the publisher to propose a clear disclosure accompanying the recommendation. If the relationship itself is misstated, correct that factual description first. Name the public location, the person controlling it and the person who will review the result. Do not mark the task complete merely because a policy was updated.

After publication, compare the requested change with the actual endorsement and disclosure together. Retain the observation date and the remaining question, if any. That record establishes what was visible at the checked placement; it does not establish an enduring result across the partner network or replace reasonable ongoing monitoring.

For a Prism website-review consultation, bring the authorized public URLs, a nonsensitive summary of the relationship and the placement question. Prism’s storefront-review scope, deliverables, responsibilities, fees and terms are discussed before work. Legal questions belong with qualified counsel and account decisions with the provider. The public inquiry asks for the website, products and question; leave out passwords, card details and customer records. Email follow-up does not book an appointment, purchase a review or submit a processing application.

Endorsement disclosure map

Complete one map per real endorsement placement. Use private business records to establish the relationship, but retain only a nonsensitive summary here. Record the view and date: a separate policy, a publisher’s assurance or an unobserved placement cannot fill an observation gap.

Worksheet entries are not submitted by Prism’s worksheet and are not saved by the site. Use record types, availability, anonymized observations, or match/mismatch results. Do not enter government identifiers, customer names or addresses, customer messages, receipt-access links, card or bank details, passwords, or keys. Send sensitive documents only through the provider’s verified secure channel.

These are temporary notes. Leaving or reloading this page may clear them. Worksheet entries are not sent automatically. If you copy notes into the consultation message and submit the form, Prism receives them as part of your request.