Advertising & Marketing

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Advertising & Marketing Standards & Guidelines

Approved: September 2024.

Purpose 

The Advertising and Marketing Standards and Practice Guidelines (“the Standards”) pertain to advertising and marketing in the context of promoting dietetic services and products within the scope of dietetic practice. Standard statements articulate the minimum level of performance expectations that must be met for the safe, competent, and ethical practice of dietitians. Practice guidelines provide suggestions and recommendations recognizing dietitians achieve safe, competent, and ethical dietetic practice in multiple ways.

The standards are intended to serve the public (our clients), who place their trust in dietitians’ expert advice when seeking to address their health and well-being through diet and nutrition. The standards are intended to guide dietitians, the College and its committees when considering dietitian practice or conduct. Dietitians should also consider their organizational and/or any employer advertising and marketing policies. These are meant to be used with relevant legislation, the Code of Ethics, and other College standards and guidelines.

Relevant legislation would include the Competition Act, which applies to advertising and marketing in dietetic practice, and Canada’s Anti-Spam Legislation (CASL), which protects consumers from misuse of digital technology, like internet marketing. Dietitians must comply with applicable laws when providing dietetic care.

Standards are necessary to ensure dietitians’ food and nutrition expertise is safely, ethically, and competently exercised on their clients’ behalf. Having the title “registered dietitian” indicates a professional obligation, and social contract with the public.

Standard Statements

Standard 1: Dietitians must ensure their advertising and marketing is truthful and accurate.

A registered dietitian demonstrates the standard by:

  1.  Providing factual, evidence-informed, easy-to-understand     information when promoting dietetic services, products, and fees.
  2.  Avoiding false, fraudulent, deceptive, inaccurate, misleading, or unfair statements, or claims that could improperly influence consumer behaviour.
  3. Understanding and applying criteria for acceptable advertising and marketing in Canada.
  4. Reviewing advertising and marketing placed by others on their behalf (e.g., employers or third parties) to ensure it meets the minimum expectations in the Standard and complies with any relevant guidelines and legislation. If not, dietitians take reasonable steps to correct the advertisement and document the steps they have taken.

Standard 2: Dietitians must ensure their advertising and marketing is ethical and professional.

A registered dietitian demonstrates the standard by:

  1. Providing transparent disclosure and including clear and prominent terms and conditions, as required by law, when offering gifts, giveaways, incentives, discounts, prizes, promotions, loyalty or bonus points, and contests for or towards dietetic services to consumers, or other products related to the practice of dietetics.
  2. If seeking or using a professional endorsement by another healthcare professional, ensuring the endorser[1] has both sufficient expertise and personal knowledge of the dietitian’s competence, and that such an endorsement supports the public in accessing relevant dietetic services.
  3. Not soliciting individual or potential clients for unrequested dietetic care by directly contacting them (e.g. by phone). It is acceptable to solicit business if clients are groups or organizations and if the solicitation otherwise complies with CDO standards and relevant legislation.
  4. Ensuring advertising and marketing, including website social media pages and accounts, does not display the College of Dietitians of Ontario (CDO) logo as they misleadingly imply an endorsement by CDO.

Practice Guidelines:

Dietitians are encouraged to:

  • Review any advertising and marketing to ensure consistency with principles of equity, diversity, inclusion and belonging, to demonstrate caring and respect of the wellbeing of the audience.
  • Consider how the dietitian’s overall advertising and marketing profile, and partnerships, align with the interest of the health of the public and shapes the public’s understanding, perception, and inherent trust in the profession (e.g. consumers should be able to distinguish a dietitian’s expert recommendation versus endorsement of a product or service).
  • Target advertising to groups of clients versus individual clients (e.g. newsletter, social media post) to avoid direct solicitation.
  • Consider if laws in other jurisdictions may apply to advertisements or marketing seen by consumers in other jurisdictions (e.g., United States). While many countries have similar laws and policies related to endorsements, dietitians may need to check and confirm other guidelines (e.g., Federal Trade Commission endorsement guidelines).
  • Consider careful use of photos (e.g., before and after) or videos of clients, ensuring that they are accurate, portray typical outcomes and inform clients that outcomes may vary. Images should:
    • be presented without manipulation (e.g. filters, artificial intelligence).
    • only be used if the client (or their substitute decision maker) has expressly consented to the use of the photo regardless of being identified or de-identified. Photos should not contain a testimonial statement.

[1] An endorser is someone who shares their experience, views, or opinions of a dietitian registrant.

Standard 3: Dietitians must actively avoid conflicts of interest in advertising and marketing.

A registered dietitian demonstrates the standard by:

  1. Avoiding and preventing conflicts of interest, and situations that could be potential or perceived conflicts of interest, wherever possible when advertising and promoting products and dietetic services, including on social media.
  2. Consistently identifying all relationships that could potentially constitute conflicts of interest. This includes identifying any opportunity for personal gain or financial or material connections with entities that have an interest in the outcome of a dietitian’s advice, recommendation, or judgment; and recognizing that such relationships risk undermining the dietitian’s primary obligation to exercise independent, expert judgment on a client’s or the public’s behalf.
  3. Managing all unavoidable conflicts of interest through transparent reporting and reorganization of roles and responsibilities to ensure independent judgment, the priority of client and public interests, and professional integrity.
  4. Transparently, consistently, and meaningfully disclosing all interactions with any entity with a financial or other material connection that could be broadly relevant to the dietitian’s advice or activities. This includes, but is not limited to, product endorsements, brand partnerships, sponsorships, ambassadorships, affiliate links, marketing programs and/or refer-a-friend marketing. Each disclosure must include a statement explaining the entity’s relevance where it would improve transparency (e.g. trade association X sponsored this event which lobbies on behalf of the X industry).
  5. Carefully considering whether to accept a gift, discount, or other benefit from an advertiser or other third party. If it could create an actual or perceived conflict of interest, avoid any gifts, giveaways, or prizes including advertising a product on the basis that the company offered a gift or other personal benefit. At a minimum, any such benefit received by a dietitian must be disclosed, even if it is not an endorsement.
  6. Complying with any applicable advertising laws, standards, and guidelines, including the Standards and Guidelines for Professional Practice – Conflict of Interest.
  7. Avoid using the RD title to promote non-dietetic practice (business or hobby). Be aware of conflicts of interest that could arise when a dietitian leverages the title to promote unrelated products or services through a social media account that identifies them as a dietitian. For example, promoting a non-dietetic jewellery business or endorsing an airline, when using the RD title.

Practice Guidelines

Dietitians are encouraged to:

  • Evaluate the potential risks posed by all conflicts of interest. For example, consider whether the endorsement of a specific brand or product is transparent, honest, evidence-informed, ethical, is consistent with the interest of health of the public, and upholds the reputation of the profession.
  • Before entering into any business relationships relating to advertising or marketing, conduct a thorough review and evaluate the potential for conflicts of interest and the severity and magnitude of the risks involved. This may include the risk of failing to prioritize clients and the public interest, the risk for reputational damage, and loss of public trust in the profession.
  • Carefully consider whether any lead generation service complies with all relevant legal and ethical requirements, including conflict of interest standards and advertising standards.

Standard 4: Dietitians must be accountable and responsible in their advertising and marketing.

A registered dietitian demonstrates the standard by:

  1. Avoiding statements that imply or state a dietitian’s services are better than those offered by other dietitians.
  2. Presenting information clearly and understandably, avoiding ambiguity or confusion.
  3. Avoiding the use of an inappropriate term, title, or designation in respect of a dietitian’s practice (e.g., using the word “specialist” title, or modifying RD title or self-description).

Practice Guidelines 

Dietitians are encouraged to:

  • Provide the public with information about their RD practice, such as information on the types of services available, the dietitian’s education and training, and accurate and verifiable statements about any additional training, qualifications, and services.
  • Avoid claiming or implying expertise that is misleading or suggests guaranteed outcomes to clients regarding dietetic services, products, and fees.
  • Consider clarity in advertising and marketing, such as using easy to understand language.

Standard 5: Dietitians must not solicit clients, former clients or caregivers for testimonials or reviews, nor post or link to testimonials or reviews.

A registered dietitian demonstrates the standard by:

  1. Ensuring advertising and marketing within the dietitian’s control does not include, link to, or solicit reviews. This could include Google reviews, insurance, and other industry, or health professional rating sites.
  2. Not incentivizing clients and others to provide testimonials or reviews of a dietetic service or product.
  3. Taking reasonable steps to remove testimonials from advertising, including contacting your employer or third party (e.g., a marketing agency) to explain professional obligations for advertising.

Practice Guidelines:

Dietitians are encouraged to:

  • Consider how they interact with public review sites and comments made by clients or others.
  • Consider use of aggregate evaluation data to advertise services instead of individual client testimonials.

Glossary

Advertising or advertisement: Any communication or message whether paid or unpaid in a public space that promotes a registrant dietitian, their dietetic services, clinic, practice, or related products. The content is either controlled directly or indirectly by the dietitian and the intent is to influence choices, opinions, or behaviour of clients or the public.

Affiliate (links, marketing, or programs): a marketing arrangement/strategy where monetary commission (or something of value) is provided when one party promotes another party’s product or service. This might be in response for traffic or purchases to an organization’s website, social media post or other content. For example, a benefit may be given to the dietitian, or a discount may be provided to the dietitian’s clients or followers in exchange for number of client visits, client sign-ups or sales.

Ambassador: see partnership.

Brand promotion: see promotion.

Client: the recipient of dietetic service regardless of setting (e.g., an individual, population, employee, business, employer, or agency).

Deceptive or misleading (advertising): advertising material information that has the capacity for influence, that is not based on evidence or fact or leads the audience to believe something inaccurate or leaves out key information.

Endorsement: represents the experience, views, or opinions of a dietitian. Endorsement of a product, dietitian colleague or other professional may entail an exchange between the dietitian and a third party (i.e., free product in exchange for writing about it/them; financial incentive with the expectation that the user will promote and discuss the product/person on social media). Endorsement typically entails some personal (e.g., career advancement, recognition, status) and/or financial gain. An endorsement differs from a recommendation.

Gifts, giveaways, and prizes (for clients, consumers, and the public): there is a distinction between gifts and prizes. A gift may be considered something that is typically offered free to a significant proportion of consumers. Gifts may be conditional, provided financial obligations are clear, and there is an additional benefit to consumers. A prize is typically something awarded, and the rules must be clear to those participating.

Control (re: advertising and marketing): the degree to which dietitians have, as opposed to others, control over the marketing and advertising messaging in their practice.

Lead Generation: process of attracting and generating consumer interest for a product or service and converting that interest into a sale or client. Some agencies provide this lead generation service to businesses through a variety of sources or activities (e.g. digital marketing, telemarketing, etc.).

Marketing: the activity or business of promoting and selling products or services.

Material connection: a connection between a producer or provider of a product or service and a dietitian that affects how a consumer evaluates the dietitian’s independence from the product, service or person being promoted. Material connections may affect the weight and credibility of the message and include but are not limited to exchanges of value such as payments (money or commission), employment, free products, services, discounts, gifts, contest entries, free trips or tickets to events, other perks, as well as, personal or family relationships.

Promotion, including brand promotion: advertising or marketing of a product, service, organization, person, or venture with the goal of increasing sales, growing a target market, or raising public awareness of a service and product available for purchase. Promotion may include brand promotion – promotion of a specific type of product by a specific company under a specific name – or unbranded promotion, such as promotion and raising public awareness around a condition for which the promoter markets a service or product that serves as a treatment.

Partnership, including brand partnership, ambassadorship, or exclusivity: an agreement to collaborate between a dietitian and two or more parties to create or promote products or services. Partnerships may include engagement by brand – where dietitians and other parties may have various levels of control and responsibility. This may include employment, engagement for a period, with roles, responsibilities, deliverables, and time set out via a contract.

Recommendation: suggestion or advice regarding the use of a specific product, appropriate to client and public needs. Should be evidence-informed and may represent a dietitian’s experience, views, or opinions. Recommendations do not have any personal or financial gain (i.e., no exchange between the company and user, no expectation that the user will promote and discuss the product on social media). A recommendation differs from an endorsement.

Review: description or rating reflecting an experience with a registrant, product or dietetic services that is managed by an independent third party with no relationship with the registrant or an employer of a registrant (e.g., Google reviews, independent website star ratings, etc.). The content of reviews is not easily removed or controlled. A review differs from a testimonial.

Solicitation: offering a good or service for purchase. This includes actively targeting, contacting, or attempting to contact an individual or a client directly, for dietetic services that is not being sought from the client themselves. Responding to client-initiated contact is not direct solicitation.

Sponsorship: One party provides financial, material, resources, or other support to a dietitian in exchange for the opportunity to promote the party’s products or services.

Testimonial: A client testimonial is a personal testament or statement from an individual client, former client or caregiver about the services received from a dietitian. The statement may affirm the performance, quality or value of a registrant, product, or service. Testimonials are chosen by a registrant, organization (e.g., employer) or third party, and these users have influence over the testimonial’s content and visibility. A testimonial differs from a review.

Verifiable: supported by evidence and science if making any scientific or nutritional claims.

 

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