My Fellow Scarabaeinae…

Whisky has been good to me. From the first time I wrote about it in a newspaper almost ten years ago, I have been on many amazing junkets at home and abroad, and I have been sent many bottles and a continuous supply of samples. This isn’t humblebragging, but it’s important to note that while I don’t work in the industry, I kinda work with it (or against it, depending on who you ask). I am whisky-biz-adjacent; think of me as one of those feeder fish, swimming alongside a whale and nibbling at parasites on its skin, or perhaps some sort of dung beetle. In short, I have my place in the ecosystem. 

I reside in a hinterland, like most whiskey bloggers, coughing up the odd post and getting the odd freebie, but getting no closer than that. But even that role comes with a certain amount of responsibility. Nobody is sending me samples, bottles, or off on jollies because of my shining personality. They do it because they want coverage, and this behaviour is really nothing new. When I worked in a newspaper we were inundated with gifts, junkets, books, concert tickets. I have a very clear recollection of declining a four-day, all expenses paid trip to an electronic music festival in Copenhagen (The Bug was headlining!) as I simply couldn’t be bothered. That is how entitled and spoiled we were. So when we think about entitled social media influencers swanning around like they are demigods, please be assured that they are simply the latest iteration of a very old tradition. Influence used to be held by entities such as publishers, now it is held by individuals, and it’s a lot harder to enforce rules when you are dealing with multiple entities across multiple platforms in multiple markets. But hey, you gotta try, especially where booze is concerned. 

The International Alliance for Responsible Drinking (IARD) is the body which oversees and decides the rules for influencer marketing in spirits. Last year they released the Influencer Guiding Principles – five specific rules that apply to any content involving influencers who work with beer, wine, and spirits producers. Of course the first task here is to figure out what is meant by working with and what is working for, along with what an actual influencer is. The IARD has a handy definition: 

An influencer is an independent third-party endorser who shapes audience attitudes through blogs, posts, tweets, and the use of other social media including game streaming platforms.

I would suggest that this definition is so vague that it technically encompasses everyone with a social media account, or 99% of the people on the internet. Endorsing is what we do when we share our opinions on things – doesn’t matter if it’s a restaurant, a whisky, a politician. In my own definition, an influencer is at its lowest level, someone who got something for free because of their profile. Anything from that benefit-in-kind benchmark onwards is what I would call an influencer. That doesn’t narrow it down much from ‘everyone on the internet’ but it is headed in the right direction, as the IARD definition of influencer marketing draws a line between those offering thoughts or opinions on a product they paid for and those who either got it for free or are being paid in some way: 

Influencer posts are considered marketing (instead of user generated content) when the influencer has received compensation through financial remuneration or there has been some form of editorial control by the advertisers (European Advertising Standards Alliance (EASA) definition).

So it’s not technically influencer marketing to get a bottle of whisky for free, but is it when the firm offers some form of editorial control – which again is a little vague. Is sending through the press release about the bottle editorial control, is saying ‘we hope you like it’? There are simple and gentle acts of persuasion that could fall under the banner of ‘editorial control’. I presume they mean a more formal, concrete version, like ‘share this at this time with this caption please’. But it goes to show that influencer marketing is only going to get bigger. 

The IARD’s five guiding principles (to which the Irish Whiskey Association and the Scotch Whisky Association have both signed up). They are: 

1.  Where available, all paid influencers must use age-affirmation mechanisms on digital platforms to prevent minors from seeing this content. Age-affirmation mechanisms on posts has not yet been adopted by all platforms and IARD members will continue to advocate for effective age-gating mechanisms on sites used by influencers. When utilizing those platforms where age-affirmation mechanisms for influencers are not yet effective, paid influencers should be aged at least 25 years and primarily appeal to audiences above the legal purchase age. 

2.  Influencers used in the digital marketing and advertising of alcohol should be vetted and, to the best of the producer’s knowledge, should have no reputational association with harmful use of alcohol, and should not feature posts that would not be compliant with the standards around irresponsible drinking behaviors outlined in our alcohol marketing codes. 

3.  For paid content, all influencers should have a written agreement with the beer, wine, and spirits brand or its agency, signed by both parties. 

This should include: 

a)  Information linking to legal requirements relevant to national or regional context, or both 

b)  Disclosure guidelines – asking influencers to clearly and conspicuously disclose their link to the brand so that it is clearly presented as marketing content 

c)  Responsibility guidelines – asking the influencer to comply with the company’s responsible marketing code including ensuring that content does not condone or encourage illegal behavior or excessive consumption 

d)  Best-practice tools for influencers when engaging on social media platforms, for example, information on branded content pages and details on how to age restrict their posts 

e)  Feedback mechanisms so that influencers can flag any engagement or issues around responsible drinking with an agency or brand 

For content featuring gifted products, influencers should be provided with clear terms of engagement that include disclosure guidelines and a requirement to follow the company’s responsible marketing code. 

4.  Influencer posts must be monitored by brands or their agencies for compliance and the influencer should fix or remove them within 72 hours if they are not compliant. If the influencer does not address issues within 72 hours of notification, or repeatedly posts non-compliant material, then we will reassess our relationship with them. 

5.  Brands should regularly audit and monitor campaigns for compliance.

And my typically incoherent thoughts on each: 

  1. Age gates – so a booze-based OnlyFans then? Honestly, how is anyone supposed to ensure no kids see the content – it’s the internet, if you want to protect our blessed innocents, maybe don’t let them online in the first place. I have four kids and the least of my worries is that they will be exposed to influencer-led alcohol marketing. There is a wild west out there and children are seeing things they never should, and, no, I’m not talking about Shit London Guinness. As for age gates, I have repetitive strain injury from clicking boxes to assure various sites that yes I am old enough to drink, and then some. Do we really think a 14-year-old is going to go elsewhere when confronted with one? Or will they giddily click through to The Forbidden Zone Of Delight that is the corporate page of a global drinks giant?

    As for influencers trying to focus their appeal on those above the legal drinking age, the clearest example of this notion gone wild is in what happened to the late, great Scotch Trooper, who took beautiful photos of Star Wars figures and bottles of scotch and landed himself in hot water for it. I would make the case that when it comes to using Star Wars figures in your booze content, you will mostly appeal to middle aged Comic Book Guys like me rather than my kids, who are all busy playing Fortnite.   
  1. Vetting influencers, best of luck with that. Maybe whoever owns Proper Number Twelve  could do the same for their influencer in chief. 
  1. Contracts would be great and I assume that for larger campaigns involving serious celebrities/influencers, they are de rigeur. However, much of what I am concerned with here is the nano-influencer who has less than ten thousand followers on their social media channels, but creates high-value, highly targeted content. Should they get a contract and presumably a non-disclosure agreement with every free bottle they get sent? Certainly the bottles I receive never come with clear terms and conditions, nor do they appear to be in any way transactional. But I think most whiskey lovers know what’s up when they get a bottle/sample – you need to mention it somehow, and the brand would be very hopeful that this mention would be positive. Perhaps that is what differentiates influencer marketing with someone like me being sent a bottle – there are no guarantees that I, or any other blogger, will say anything nice about it. 
  1. Would a post, even one laden with errors, be of any relevance after 72 hours up? Is there any point in correcting it? If the influencer was big enough, the post will already have achieved millions of impressions in that time. And who is meant to contact them to tell them to edit the post? PR firms – who I assume do a lot of the influencer outreach/management stuff for drinks brands – won’t want to piss off the bigger accounts. It really smacks of self regulation, a system which has worked so well in the financial markets worldwide. 
  1. ‘It’s on you guys’. 

If I could write rules for low-level whisky influencers it would be this – if you got it for free, say so. I just don’t think anyone can judge a product with absolute clarity and honesty when they didn’t pay for it. I look back on some whiskeys I have reviewed where I got the bottle for free and in retrospect I was too gentle on something that really didn’t deserve it. Why? I would say it was less about staying in with a brand and more about not wanting to be an ungrateful twat. Either way it was misguided. More recent reviews of free bottles have been a little less delicate about their failings, which really is as it should be. 

Not paying for the whiskey you are reviewing is a crucial context and the one that applies to most of the whiskey folks that get labeled as influencers. It’s also important to just say thanks to whoever sent it to you, which is what I do when I get free stuff. 

If you are being paid actual money to promote the whiskey than you need to clarify that you are, in fact, the same as a guy on the street wearing a sandwich board advertising a golf sale down a side street. We all gotta hustle but there’s a big difference between saying you like a product and literally working for the brand – although an obvious caveat here is that I don’t know of anyone who was paid to post anything about a whiskey, nor do I know anyone with a big enough following to even warrant that approach. Most of us are just happy dung beetles, just lovin’ life rolling our free balls of poop to a hole in the ground. 

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