A disclosure policy for an agency website that covers authorship, testing and client ties

A page-level disclosure record should name the author, editor, fact-checker and reviewer, set out evidence and relationships, and give a route to challenge the page. It does not replace an advert label, privacy notice, contract term or legal review.

This method is for an England-based agency or publisher. The cited advertising and consumer sources have UK scope. No client, provider, test, review or commercial relationship is asserted here.

What to take away

Create a page-level disclosure record

For every guide, comparison, case study, testimonial or supplier page, record:

Use none declared only after the responsible person has answered. Unknown is more accurate when a check is incomplete.

Filled-in example, using role labels rather than personal names:

Where to place the disclosure

Committee of Advertising Practice (CAP) Code Section 2 requires marketing communications to be identifiable and says advertorials must be made clear. Place a paid or affiliate disclosure above the first claim, price, rating or call to action.

Put a second line in the byline block. If a table ranks providers, repeat the label in the table header row. A policy linked from the footer does not necessarily make a commercial article obvious.

Use plain descriptions such as who paid, what they could control and whether the link can generate revenue. Do not rely on an ambiguous label or a relationship disclosure placed after the claim.

Worked example for a paid or affiliate agency page:

Paid partnership with [provider]. [Provider] paid for this placement and did not approve the surrounding editorial. Written by our named content editor. Reviewed by our named qualified reviewer on [date]. This page contains affiliate links. If you buy through them, we may earn a commission. Commission does not affect selection or testing.

Describe evidence and testing honestly

A provider comparison should state the selection method, common criteria, evidence date and exclusions. Distinguish a public-document review from account access, a demonstration from independent testing, and a supplier case study from verified client evidence. Never convert access to one feature into a product-wide verdict.

For testimonials and consumer reviews, record authenticity, permission, incentive, moderation and removal process. The Competition and Markets Authority (CMA) reviews and endorsements guidance collection gives separate guidance for businesses, platforms and content creators. It does not validate any review on an agency site.

Objective claims still need substantiation. CAP Code Section 3 addresses evidence, qualifications, comparisons, testimonials and price presentation. A conflict disclosure cannot rescue an unsupported result or conceal a material limitation.

Keep privacy information separate

If a form collects reviewer, client or reader details, provide appropriate information about the controller, purposes, recipients, retention and rights. The Information Commissioner's Office (ICO) right-to-be-informed guidance explains the UK GDPR transparency minimum. This is a different record from editorial conflicts.

Do not publish a client's personal data, confidential metrics or identifiable quotation merely because it is commercially favourable. Check authority, purpose, data protection, confidentiality and IP rights independently.

Operate corrections and withdrawals

Place a visible route for reporting an error or undisclosed relationship. Log the report, owner, evidence, interim action, decision and date. Correct the claim and its dependent pages, or withdraw material while a serious issue is unresolved. Preserve a change note unless doing so would itself expose restricted information.

Typical timelines: acknowledge within 2 working days, take interim action within 5 working days, and complete the final correction within 20 working days. Shorten these for safety, legal or ongoing consumer risk.

Minimal correction log. Copy these columns:

Reconfirm relationships and source status on each scheduled review and before republication. Named advertising, consumer, privacy, IP and commercial reviewers must approve the actual policy and its use. This draft gives no compliance assurance.

Before you act

Common questions

What should a page-level disclosure record include?

It should record named author, editor, fact-checker and qualified reviewer, plus research date, subject, source universe and exclusions. It should also cover documents opened, first-party claims, hands-on work, environment, untested areas, relationships, payment or sponsorship, rights and permissions, publication date, last check, correction owner and withdrawal trigger.

Where should a disclosure appear?

See the placement section above for the byline block and table header positions. A footer policy alone is not enough.

How should an agency handle corrections and withdrawals?

Provide a visible route for reporting an error or undisclosed relationship. Log the report, owner, evidence, interim action, decision and date. Correct the claim and its dependent pages, or withdraw material while a serious issue is unresolved. Preserve a change note unless it would expose restricted information.