Sponsored Content Disclosure Policy

Summary. Every Campus Voices post is an ad, and it has to look like one from the first second and the first line. The creator puts the approved disclosure at the very start of the caption, shows an on-screen "Ad" or "Sponsored by" line for at least the first 3 seconds, turns on the platform's paid partnership setting, and says it out loud when talking to camera. A reviewer cannot approve a draft that misses any of these, and a live post that drops them is not verified and is not paid until fixed.

Version: 0.1 (draft). Owner: TTplus10 Inc., doing business as Campus Voices and Campus Voices Media ("Campus Voices", "we"). Applies to: every Creator, every Campus Voices reviewer and verifier, and every University reviewer in UNIVERSITY approval mode.

1. Why this policy exists

1.1 A Creator paid to post about a University is making an endorsement. The paid relationship is a material connection that viewers do not expect, so it must be disclosed clearly and conspicuously (16 CFR 255.5). In social media the disclosure should be "unavoidable" (16 CFR 255.0).

1.2 The advertiser (the University, or Campus Voices in the Independent Test) and Campus Voices as the intermediary can be liable for an endorser's missing disclosure. The FTC expects advertisers to tell endorsers what to disclose and to monitor them (16 CFR 255.1 and 255.5, the college student points program example). This policy is how we do both.

1.3 TikTok and Instagram separately require their paid partnership settings on branded content. A post that breaks platform rules can lose distribution or be removed, which hurts the Creator and the University.

1.4 This policy is written so the software can enforce it. Each rule in sections 3 to 8 maps to the review check DISCLOSURE or the verification check DISCLOSURE_PRESENT in src/server/domain/checklists.ts.

2. Definitions

2.1 Sponsor: the party whose money pays for the post. In a University Program it is the University, whether the University pays through Campus Voices or pays the Creator directly. In the Independent Test it is Campus Voices.

2.2 Sponsor Handle: the Sponsor's official account handle on the platform where the post goes, recorded on the Brief per platform. For the Independent Test, the Campus Voices handle on that platform. Campus Voices has not yet secured a handle on every platform (the Instagram handle @campusvoices belongs to someone else), so every document uses the placeholder @[CampusVoicesHandle] until the founder secures one on TikTok and Instagram. No Independent Test Brief may be published until the real handle is filled in.

2.3 Disclosure Line: the exact text that must open the caption, stored on the Brief as disclosureText.

2.4 On-Screen Disclosure: text burned into or overlaid on the video.

2.5 Platform Label: TikTok's "Paid partnership" label produced by the commercial content disclosure setting with "Branded content" selected, and Instagram's "Paid partnership with [partner]" label.

2.6 First Line: the caption text a viewer sees before tapping "more". We treat it as the first 60 characters of the caption and the first line break, whichever comes first, because truncation length varies by device and platform [verify current truncation lengths; we choose a conservative number on purpose].

3. The four required elements (all cases where a Creator posts)

Every sponsored post from a Creator's account must carry all four of the following. Missing any one is a DISCLOSURE fail.

3.1 Caption. The caption must begin with the Disclosure Line. Nothing may come before it: no emoji, no hook, no mention, no line break. The whole Disclosure Line must sit inside the First Line.

3.2 On-screen text. The video must show the On-Screen Disclosure from 0.0 seconds for at least the first 3 seconds. Rules for legibility:

• (a) Text height at least 4% of the frame height (about 77 pixels on a 1920 pixel tall frame).
• (b) High contrast: white text with a dark outline or backing box, or dark text on a light box.
• (c) Placed in the upper two thirds of the frame and away from the right edge, so the platform's own buttons and caption do not cover it.
• (d) Not animated in a way that makes it unreadable (no fast flashing, no scrolling off in under 3 seconds).
• (e) In English, and in the same language as the rest of the video if the video is in another language.

3.3 Platform setting. The Creator turns on the Platform Label when posting (section 6).

3.4 Spoken disclosure. Required whenever the Creator speaks to camera in the post. The Creator says one of the approved spoken lines in section 4 the first time they speak to camera, and within the first 10 seconds of the video if they speak to camera that early. If the Creator does not speak to camera (for example a video with only music, natural sound or on-screen text), the caption and on-screen text are enough. For a voiceover with no talking to camera, a spoken line is recommended but not required.

4. Case by case requirements

4.1 Case 1: University Program, Campus Voices pays the Creator (default)

Note on Campus Voices' role: Campus Voices is the manager, not the Sponsor, in Case 1. Mentioning Campus Voices in the caption is not required and is not a substitute for naming the University.

4.2 Case 2: University Program, University-Paid Option (University pays the Creator directly)

Identical to Case 1. The Sponsor is the University. The payment route does not change what the viewer must be told.

4.3 Case 3: Independent Test (Indiana University Bloomington proof program)

4.4 Case 4: University reposts Approved Content on a University Owned Channel

4.4.1 The University is the speaker on its own channel, so no Creator-side disclosure is needed on the University's post, and the Creator does not post anything.

4.4.2 The University must not present the content as an unsponsored or spontaneous student testimonial. The FTC's endorsement examples say that when an advertiser reposts an endorser's content that lacked a disclosure, the advertiser should add one. The student's paid relationship is not obvious just because the account is the University's.

4.4.3 Required caption credit: the University's caption must tell viewers the student was paid. Approved forms: Paid student creator @[creator] or Created by @[creator], a paid [University] student creator. A bare Created by @[creator] or Created by @[creator] for [University] is not enough. This obligation sits in the MSA (founder resolution 10).

4.4.4 The credit goes at the start of the University's caption, inside the First Line, on the same terms as section 3.1. Where the Creator has asked not to be credited by handle, the University uses Paid student creator without the handle.

4.4.5 Banned University framing: "a student shared", "unsponsored", "real review", "what students really think" or any wording that implies the Creator was not paid.

4.4.6 The University may crop or trim out the Creator's on-screen "Ad" text under the Organic License edits, but only if the University's own caption carries the credit in 4.4.3 or 4.4.4.

4.4.7 Music on reposts is governed by 09-music-and-content-rights-policy.md: the University reposts the Version B clean file, not a download of the Creator's platform post.

4.5 Case 5: Paid media (only under a signed Paid Media Rights Addendum)

4.5.1 Paid media is never part of the Organic License. It needs a Paid Media Rights Addendum per asset.

4.5.2 Spark Ads (TikTok) and partnership ads (Meta). These run from or through the Creator's own post. The underlying organic post must already meet Case 1 in full (caption, on-screen text, platform setting). The platform adds its own "Sponsored" label to the ad; that label says it is an ad but not that the Creator was paid, so the Creator's disclosure stays.

4.5.3 Dark posts and University-run ads using Version B. The ad runs from the University's ad account. The platform's "Sponsored" label is required and automatic. Because a real student's first-person testimonial appears in an ad, the ad copy or on-screen text must also say the student was paid: Paid student creator on screen for at least the first 3 seconds, or in the first line of the primary text [counsel: see Notes item 4].

4.5.4 Whitelisting. Access only through platform tools (TikTok authorization codes, Meta partnership ads permissions), never by sharing a password. The Creator's caption rules in Case 1 still apply to anything posted as the Creator.

4.5.5 Every recognizable person in a paid media asset needs a signed release, and music must be cleared for ads (see the music policy).

5. Banned forms

5.1 The following never satisfy this policy, alone or together:

• (a) Disclosure only at the end of the caption, or inside a block of hashtags.
• (b) #sp, #spon, #collab, #partner, #ambassador alone, or any abbreviation that is not "ad" or "sponsored".
• (c) "thanks to [University]", "shoutout to", "in collaboration with", "proud to work with" or "ambassador" alone.
• (d) Disclosure only in the profile bio, a pinned comment, a reply, a story highlight, or a linked page.
• (e) Disclosure only via the Platform Label.
• (f) Disclosure only by voice, or only on screen.
• (g) On-screen text that appears after 0.0 seconds, lasts under 3 seconds, is too small, low contrast, or covered by platform buttons.
• (h) Disclosure hidden by white-on-white text, tiny font, or characters that look like "ad" but are not (for example, look-alike Unicode letters).
• (i) Editing the caption after verification to remove or move the Disclosure Line.

5.2 #sponsored, #ad, Ad, Sponsored by and Paid partnership with are allowed as the lead words only in the exact forms in section 4.

6. Platform settings, step by step

6.1 TikTok. On the post screen, open "Content disclosure and ads" (on some accounts under "More options"), turn on "Disclose commercial content", select "Branded content", and add the Sponsor as brand partner where the search finds the Sponsor's account. TikTok then shows "Paid partnership" on the video. For an already posted video the setting is under the video's "More options", then "Ad settings" [verify menu labels at time of use; TikTok renames these often].

6.2 Instagram. The Creator needs a professional account (Creator or Business) to use the label [verify]. On the Reel's advanced settings, turn on "Add paid partnership label" and add the Sponsor's account as brand partner. The label appears as "Paid partnership with [partner]" once the partner approves, or at once if the partner has pre-approved the Creator.

6.3 If the label cannot be added. Possible reasons: the Creator has a personal Instagram account and declines to switch; the University has not approved the partner request; the Sponsor has no account on that platform. Then:

• (a) the caption and on-screen requirements still apply in full;
• (b) the Creator still turns on the setting without a partner tag where the platform allows it;
• (c) the verifier records the reason in the verification note (see section 9.3); and
• (d) Campus Voices asks the University to pre-approve Program Creators as partners on Instagram, so the label is automatic.

6.4 The Creator attests at upload that they understand and will turn on the setting (disclosureUnderstood). The verifier checks the label on the live post (section 9.2).

7. Compliant and non-compliant examples

In the examples, @stateu stands for the University's handle.

7.1 Compliant (Cases 1 and 2)

• #ad @stateu Move-in day is Aug 18. Here is what I wish I packed.
• Paid partnership with @stateu. The new rec center is open until 11 pm.
• On screen from 0:00 to 0:04: Sponsored by State U.

7.2 Compliant (Case 3)

• #ad Paid partnership with @[CampusVoicesHandle]. Not affiliated with IU. My 3 favorite study spots on campus.
• On screen from 0:00 to 0:03: Ad, paid by Campus Voices.

7.3 Non-compliant

• Move-in day is Aug 18! #college #dorm #ad (disclosure at the end, buried in hashtags)
• POV: first week #ad @stateu (hook before the disclosure)
• Thanks @stateu for having me! (thanks is not a disclosure)
• #sp @stateu campus tour (banned abbreviation)
• #collab with @stateu (banned term)
• #ad @indianauniversity best campus ever (Case 3: tags IU; the Sponsor is Campus Voices)
• Paid partnership with @[CampusVoicesHandle], the official IU creators program (claims IU affiliation)
• A caption that starts correctly but the video has no on-screen text, or the text shows at 0:05.

8. The review check: DISCLOSURE (draft stage)

8.1 A reviewer marks DISCLOSURE PASS only when every criterion below passes. DISCLOSURE cannot be NA. A FAIL must carry a note saying which criterion failed (the software already requires a note of at least 3 characters).

8.2 The platform setting cannot be seen on a draft. At review it is covered by D9. It is checked for real at verification.

8.3 Failure at review. The reviewer chooses "Request changes" with the failed criteria in the note. This counts as one of the Creator's 2 included revision rounds only if the Brief stated the disclosure correctly. If the Brief or Campus Voices gave the wrong disclosure text, the revision is on us and does not count.

9. The verification check: DISCLOSURE_PRESENT (live post)

9.1 Staff open the live post on the platform, logged out or in a private window where possible, and confirm the following. DISCLOSURE_PRESENT is confirmed only when V1 to V4 all pass.

9.2 Staff save a screenshot of the live post showing the caption start and the label (see section 11 for storage).

9.3 A missing label with a section 6.3 reason on file is a pass. A missing label with no reason is a fail.

9.4 Failure at verification. Campus Voices runs verification within 3 business days after the Creator submits the live URL (Creator Agreement Section 5.3). If it fails, the post is not verified and the fee is not earned yet. Campus Voices notifies the Creator in the app and by email with the failed items. The Creator has 24 hours to fix it:

• (a) Instagram: edit the caption or turn on the label in the post settings.
• (b) TikTok: turn on the setting in "Ad settings". If TikTok does not allow editing the caption of that post [verify current TikTok caption editing], delete the post and repost the approved video with the correct caption. The repost is the post that gets verified; the live window runs from the repost.
• (c) After the fix, staff re-run verification within 3 business days.
• (d) Payment timing follows the Creator Agreement: within 15 days after verification and never later than 30 days after the Creator first submitted the live URL.

9.5 A live post with no disclosure at all is urgent: it is a legal risk to the Sponsor. Staff treat it as an urgent removal category under 12-removal-live-window-and-conduct-policy.md (fix or take down within 4 hours where reasonably possible).

9.6 If the Creator does not fix within 24 hours, Campus Voices asks the Creator to remove the post, the assignment ends unpaid, and the matter goes to the conduct ladder (warning first). A deliberate removal of a disclosure after verification is treated as falsified compliance under the conduct policy.

10. Ongoing monitoring

10.1 The disclosure and the Platform Label must stay in place for as long as the post is live, including after the Live Window (Creator Agreement Section 9.4). At each live-window check (see the removal and live-window policy), staff re-check V1 and V4 and note any change. A disclosure removed after verification does not claw back the fee (decisions sheet: no clawbacks) but must be fixed within 24 hours and goes on the conduct ladder.

10.2 Campus Voices keeps the verification screenshot and checklist for 7 years with the audit log.

10.3 Campus Voices reviews this policy against FTC and platform guidance at least every 6 months, and whenever TikTok or Meta changes its branded content tools.

12. Creator one-page summary (give this to every Creator)

How to disclose on every Campus Voices post

Every post you make for Campus Voices is an ad. The law and the apps both say viewers must be able to tell right away. Four things, every time:

1. Start your caption with the disclosure from your brief. Copy it exactly. It goes first, before any words, emoji or hooks.
   • University programs: #ad @[university] or Paid partnership with @[university] (your brief says which).
   • Independent Test: #ad Paid partnership with @[CampusVoicesHandle]. Not affiliated with IU.
2. Put it on screen from the first second for at least 3 seconds. Use the text in your brief (Sponsored by [University], Ad, or Ad, paid by Campus Voices). Big, easy to read, upper part of the screen, not under the app's buttons.
3. Turn on the app setting.
   • TikTok: "Content disclosure and ads", turn on "Disclose commercial content", choose "Branded content", add the brand in your brief.
   • Instagram: "Add paid partnership label", add the brand in your brief.
4. If you talk to camera, say it. The first time you talk to camera (and in the first 10 seconds if you talk that early): "This is sponsored by [sponsor]" or "[Sponsor] paid me to make this." If you never talk to camera, the caption and on-screen text are enough.

Never: put #ad at the end or in a pile of hashtags; use #sp, #spon, #collab, #partner or "thanks to"; put the disclosure only in your bio or a comment; edit the caption later to remove it. In the Independent Test, never tag IU or say it is an IU program.

What happens if it is missing: at review, we send it back to fix. After posting, the post is not verified or paid until you fix it, and you have 24 hours. Removing a disclosure after we verify is a conduct issue.

Questions: hello@campusvoicesmedia.com, before you post.