Written evidence submitted by Dr Joyce Costello and Dr Sevil Yesiloglu

7 May 2021

1.       Dr Joyce Costello is a former Senior Lecturer in Digital Marketing from Bournemouth University and currently visiting lecturer at Quadriga University. Her research interests include public service motivation and the dark side of Influencer marketing.

2.       Dr Sevil Yesiloglu is a Senior lecturer in Digital Advertising and course leader for BA Advertising at the University of the Arts London (LCC). Her research interests are influencer marketing, social media and digital consumer behaviour, especially digital engagement and the impacts of social media on teenagers’ wellbeing.

3.       Dr Costello and Dr Yesiloglu, are available to provide further detail and give oral evidence as needed

Question 1: How would you define influencers and influencer culture? Is this a new phenomenon?

Influence versus Influencer

4.       For many years organisations and researchers have sought to identify key thought leaders and those who can influence others’ behaviours and change. However, in 2011 scholars began to identify a new category of individuals who were initially identified as micro-celebrities and later Influencers who are recognised as individuals being influential on individuals and their decisions. As Influencer Marketing has evolved to be an estimated $13.6 billion industry, an influencer is defined in marketing literature as "a person who has a strategic approach and ability to Influencer Individuals and their (buying) decisions within digital communications platforms"[1]. This infers a level or responsibility required by those involved with or those who identify as an Influencer.

5.       When using the term "influence culture", it suggests that there is a code of conduct that such as prescribed by the Advertising Standards Agency. This code of conduct guides the norms and behaviours of Influencers and aspiring influencers. Because being an Influencer is not currently a formalised profession and is in its nascent age, there is an opportunity for the culture to be moulded and developed into something that benefits society.

6.       Therefore, policy makers need to carefully consider how influencers are defined from a strategic point. If being an influencer is not formally defined and rules and regulations guide future operations, then society as a whole is poised to suffer through nefarious and unscrupulous practices.

Question 2: Has Influencing Impacted popular culture? If so, how has society and/or culture changed because of this side of social media?

The impact on society: Body Image and self-harm

7.       Influencers in the beauty and fashion industry have been able to influence society in ways that magazines and models have not been able too. The sheer amount of influencers on Instagram, Tiktok, YouTube and more have been able to use filters to transform photos and videos to such a degree, that the societal idea of a normal body and face may have been altered permanently.

8.       Influencers are also involved in the darker side of the web that can glamorise anorexia and other self-harms methods. Whether a severely underweight influencer is promoting weight loss gummies or weight loss coffee or glamorising surviving on less than 500 calories a day, this can persuade children and teens to take up dangerous habits. Research shows that there is a rise in self-harm and suicide with teens in relation to social media usage (https://pubmed.ncbi.nlm.nih.gov/30581202). Research in this area increased when a British father said his 14-year old daughter killed herself after looking at self harm videos on Instagram (https://www.webmd.com/mental-health/news/20190604/sould-seeing-self-harm-on-instagram-spur-copycats#1).

9.       Society has been impacting people towards to the belief that is success and high-quality life mean owning better objects. As a part of this perception of society, influencers usually execute their life in visually stimulating format on social media that can lead their followers to create false expectations about their life. Via their profile and their content, they appear to have a dream lifestyle that tend to be impossible to achieve by their followers. As a result, people begin to have unsatisfied needs about their life. And it can eventually impact users’ self-esteem and wellbeing.

10.   One prevalent issue related to wellbeing Is the promotion of unlicensed drugs. BBC reported on May 3, 2021, about influencers who were promoting weight-gain drug Apetamin and the serious health issues that resulted by taking this unlicensed drug. Advertising rules are very clear when it comes to promoting items, but focus on marketers. This causes issues as Influencers are giving “testimonials” of their own use and can claim is the equivalency of feedback or reviews.  

11.   From a regulation perspective, social media sites and influencers should be required to inform users when any images and videos are edited. Regulators need to consider providing a guidance to influencers and social media sites how they disclose any edited or filtered content on their social media accounts. Also brands which are collaborating with influencers should also be required to add to their contracts that users will be provided transparent communication regard to products influencers promote on their digital channels.

12.   The committee are recommended to consider improving regulations around harmful content shared and promoted by influencer especially to vulnerable individuals. This responsibility also needs to be shared by influencers and brands. The committee is encouraged to provide detailed auditing and controlling system to the any content shared and promoted by influencers or brands via influencers’ profile.  

Question 3: Is it right that influencers are predominantly associated with advertising and consumerism, and if not, what other roles to influencers fulfil online?

Consumerism: Selling to your friends

13.   Influencer marketing relies on the concept of electronic word of mouth. Individuals who are considered Influencers within their own niche (nano, micro, macro and mega) are asked to engage their followers through reach, relevance and resonance to purchase products and services[2]. Relying on influencer-generated content and persuasion, the social media posts fulfils the role of an advertisement albeit positioned as an influencers’ “recommendation”.

14.   There are many levels of advertising and consumerism in influencer marketing and advertising. Content can be promoted as an #ad or #sponsored, but also as #affiliateMarketing. While many brands will argue that Influencers help raise awareness about products, they ultimately promote consumerism by their very nature.

15.   As a part of advertising, influencers tend to create impulsive buying. They particularly use social media channels such as Instagram to showcase appealing content encourage users to make impulsive purchases. To strength their strategy, influencers integrate “buying tags” future on Instagram posts. 

16.   The recommendation for the committee is influencers need to provide further clarity when they advertise and promote products and services. Committee is encouraged to formalise legal boundaries related to disclose if there is a material connection beyond payment, free discount, vip access, family relationship, employee relationship, free product.

Building communities and popular culture:

17.   Influencers are considered as famous individuals who have built their presence by producing valuable and engaging content. There are several attributes influencer use in their engagement which create “sense of community” in their network (e.g. Instagram, Twitter or Tiktok). These community building activities include sharing relatable content, informative and supportive posts and original ideas/content. While informative and supportive content help users to engage with influencers’ content, relatable content tends to make users feels as a part of “friendship group”. As a result of these types of communication approach, individuals tend to feel closer to the influencers which eventually they feel part of a community. Via building communities, influencers send their messages (e.g. promotion, adverts, global issues etc.) across more efficient and effective way.

Question 4: How are tech companies encouraging or disrupting the activities of influencing?

Intermediaries

18.   Influencers who run blog pages can have content embedded through real-time advertising. Or, they could have affiliate links. Much of this can be facilitated through Google adspace. “According to Google Support, when a channel reaches 4,000 watch hours in the previous 12 months and 1,000 subscribers, it will be considered for YouTube's partner program.” This technology company rewards the influencer to engage in influencer marketing to earn money.

19.   Tiktok has taken an approach to influencer marketing with its creator market place. Using an application-based process, Tiktok uses a set of criteria to determine if those who create engaging content that attracts engagement and hence may be classified as are influencers. The organisation is seeking to monetarise influencer advertising by being the middleman by pre-screening potential influencers and arranging for relations with brands. This approach may be considered as a broker for influencer advertising and can change the way social media companies facilitate influencer advertising. On one hand, because Tiktok has full access to the creators’ data, audience engagement, metrics, etc., brands could feel more confident about influencer metrics. However, it doesn’t mean it will translate into new sales.

20.   Social media channels also create an algorithmic system encourages influencers share and produce content continually in order to increase engagement (e.g. likes, comments, views etc.). In order to meet demand social media creates for influencers, influencers begin to encourage their followers to engage with their posts through producing additional content. However, this potentially lead unauthorised over sharing on social media by influencers and their followers.

21.   Therefore, the committee is encouraged to provide clear regulations and guidance to influencers and content creators. Guidelines should enforce social media sites make the forms of sharing clear to influencers.

Question 5: How aware are users of the arrangements between influencers and advertisers? Should policymakers, tech companies and influencers and advertisers themselves do more to ensure these arrangements are transparent?

Transparency: Show and tell

22.   One of the key issues with influencer marketing that originally a rose was content that was not clearly delineated as advertising or marketing. Indeed, multiple countries have started to issue regulations which require any form of embedded advertising on social media to be labeled very clearly. van Reijmersdal et al. (2020) used eye tracking to study children from age 10 to 13 were able to distinguish embedded advertising from normal content in social media. They argued that using emotionally appealing and attention gathering features prevented children from actually noticing sponsored content tags as required by legal institutions. Well disclosure aims to let the audience know they were sponsored content, it doesn’t answer whether attitudes towards the brands may change if there is sponsored content.

23.   The clear marking of content that is advertising by influencers is an area that has been evolving in line with the rules towards native advertising. However, it is not always an element which is clear to the viewers. van Reijmersdal et al. (2020) states that children and youth are especially vulnerable when it comes to trying to decide if something is sponsored or not. van Reijmersdal et al. (2020) found that when watching YouTube influencer videos, that if the notice of sponsored content was before the video, then the children would recognise 2 1/2 times more than when the statement that the content sponsored if it was embedded in the video or in the information below -it was not as easily identifiable. This implies that the placement and the timing of sponsored content may need to be addressed as part of legal issues given evidence of tracking studies.        

24.   When influencers target children they do not consider the differing demographic backgrounds including income level. This can exacerbate the harm to a child as the product or brand may be wildly unaffordable for the family yet the strong desire to own the product remains. With non-disclose adverts by influencers, the child cannot decouple from identifying with the product or brand, and struggles to consciously consider whether they need this product or not. A potential solution is to restructure regulations around being transparent about advertising deal/partnership they have with brands.  The restructure should apply across all social media platforms.

25.   The committee is encouraged to regulate any material connections influencers have.  A focus on providing information about the product and the purpose of online advertising, rather than giving persuasive messages would be more socially responsible. Guidelines should enforce brands and influencers make the forms of advertising and sponsored partnership clear and recognisable to vulnerable audiences, particularly young children. Formal partnerships should be distinguished from informal or no partnerships.