Multilingual social marketing rules and ethics: what to record

Source register : A list that labels each reference as legislation, regulator guidance, self-regulatory code, technical guidance or contract.

Source claim : The approved statement and its evidence, geography, population, period and limitations.

Language service : The commissioned translation, localisation, transcreation or other language work, with its source version and reviewers.

Audience description : A record of who may receive the communication and how the route was chosen, without proxy inference.

Rendered experience : The final post, disclosure, destination and correction notice as encountered in a particular format.

Personal-data flow : The path from collection to deletion, including selection, upload, matching, delivery and supplier access.

Release record : The connected evidence, decisions, versions and approvals required to authorise publication and respond to change.

Use a record template before release

Complete one record for each campaign and version. Copy these fields into the release record and fill them with the evidence and decisions for that work:

Build the source map first

For multilingual social marketing rules and ethics, set up a source register before drafting begins. It identifies whether a reference is legislation, regulator guidance, a self-regulatory code, technical guidance or contract. That classification stops a platform term or ASA advice page being mistaken for an Act or for the CAP Code.

An England-based publisher may face UK data and consumer rules, the Great Britain equality framework, advertising requirements, platform terms and sector rules, each with its own question and reviewer. Check the reach of each item for the particular campaign; UK rules need not answer the same question as a contract or an advertising code.

Describe the audience without proxies

Record who controls the source claim, who publishes it, who may receive it and how the route was selected.

Do not infer language, literacy, culture, ethnicity, nationality, vulnerability, consent or buying intention from a name, postcode, profile or administrative field. Ask people to describe the language and format needed for the task.

Keep research participation, marketing selection and service delivery records distinct. Agreement to take part in research is not permission to receive promotion. A language preference supplied for one service interaction is not blanket permission for profiling, an audience upload or a creator campaign; planning mistakes can begin when those records are treated as interchangeable.

If children or adults at heightened risk are involved, name a safeguarding owner and choose a route suitable for the actual context. Language alone does not establish vulnerability. Base the decision on the population, service and risk rather than a stereotype, and record who made that assessment.

Lock the claim and language scope

The source claim belongs with its substantiation before language production starts. Record the evidence, geography, population, period, limitations and claim owner. The CAP Code requires documentary evidence for objective claims to be held before distribution, so advertising release checks should start with the approved source, not a later translation.

Name the service being commissioned. Translation transfers a controlled source, localisation adapts it for a stated locale, and transcreation permits wider creative treatment that calls for a fresh claims check. A qualified native-level reviewer should check meaning and usage for the actual language and locale; a subject specialist should check legal, medical, financial or other technical meaning.

The Government Commercial Agency's Language Services framework distinguishes translation, interpreting, transcription and machine-assisted services in a public-procurement context. It does not certify a supplier for a particular campaign. The contract should identify the service, source version, deliverable, reviewer, correction duty and permitted use.

Test the experience people encounter

The Equality Act setting is Great Britain, while public-sector website accessibility is governed by the Public Sector Bodies (Websites and Mobile Applications) (No. 2) Accessibility Regulations 2018, which have a distinct scope. Private organisations should not claim those regulations apply to them without advice.

Test the final post, video, disclosure, destination, error state and correction notice. Record the device, browser or assistive technology, language setting, asset version, task and result. The rendered experience needs its own evidence alongside language review; a translation approval does not establish accessibility.

Keep each review lane distinct

First decide whether the communication falls within the CAP Code's published scope. Then check recognition, substantiation, qualifications, prices, comparisons, testimonials, harm, children and any relevant sector section.

ASA social guidance says advertising should be identifiable in the form encountered; a platform paid-partnership label may help but does not settle wording, prominence or every format. A disclosure policy can keep relationship decisions visible.

Consumer law is a separate decision. For unfair commercial practices, identify Part 4 of the Digital Markets, Competition and Consumers Act 2024 and the Competition and Markets Authority's Unfair commercial practices: guidance (CMA207), then check the current text and guidance against the facts. Record creator gifts, affiliate arrangements, employee advocacy and own-brand relationships before drafting disclosures. Financial promotions add another regime: FCA FG24/1 concerns financial promotions on social media and explains its audience, but general advertising approval does not authorise one.

Map the personal-data flow from collection to deletion, including selection, upload, matching, delivery, tracking, support, export and supplier access. Identify who determines each purpose and means. The Data (Use and Access) Act 2025 amended UK GDPR, the Data Protection Act and PECR; check the current text and commencement position when making the decision.

The Data Protection Act 2018, UK GDPR and amended rules call for a purpose, an appropriate lawful basis, fairness, minimisation, transparency, rights, retention and security. A qualified reviewer must assess the facts, including special-category or criminal-offence data, profiling or children where present. Do not derive sensitive characteristics from language or engagement signals.

PECR is a separate lane from data protection. ICO electronic-mail guidance covers email, texts and similar stored messages, including social direct messages; storage or access technologies need their own assessment. Privacy information should describe actual processing and remain distinct from consent, an advertising label and terms. The ICO right-to-be-informed guidance treats that information as a UK GDPR transparency requirement.

Bind rights, suppliers and commercial terms

A source owner may not own every image, recording, font, testimonial or target adaptation. The Intellectual Property Office explains that use of another person's copyright material normally needs a licence, ownership or an applicable exception.

Have a qualified IP reviewer check territory, language, media, edits, credit, duration, sublicensing and use after termination.

Supplier due diligence should record legal identity, subcontractors, account permissions, confidential assets, incident duties, continuity, export and deletion. The NCSC supply-chain principles provide a UK security reference, not a supplier certificate. Record the platform terms and edition accepted by each account owner, with a date for checking changes.

A contract needs exact parties, authority, scope, source and target assets, approval order, data roles, licences, account ownership, platform-change route, fees and tax treatment. Correction, suspension, termination, export and deletion need clear terms. VAT and recoverability are finance and tax questions; HMRC invoice requirements show that VAT status affects required invoice information.

Employment status depends on the facts, and tax and employment-law status can differ. A contract calling a translator independent does not settle that question. For a covered public buyer, record the applicable procurement regime: the Procurement Act 2023 generally applies in England, Wales and Northern Ireland; devolved Scottish procurement uses Scottish rules, including the Procurement Reform (Scotland) Act 2014 and, where relevant, the Public Contracts (Scotland) Regulations 2015. Check scope, exemptions and transitional provisions. Procurement Act training describes the Act's general application and narrower Scottish role. Private buyers should not use a public-sector approval label.

Assemble evidence for release and change

Connect the source version and every target asset to their reviews, claim evidence, privacy map, disclosures, contract and named approvers. A named-owner workflow can help identify who supplies each decision; the release checklist should show where its evidence is held.

Set hold conditions before publication. Examples include a changed source claim, missing disclosure, inaccessible rendering, disputed rights, unauthorised account access or inability to withdraw a target version. Do not replace separate decisions with one general supplier-approved status: a language deliverable does not resolve a data transfer, and an Article 28 schedule does not grant copyright.

Monitor each language and format as displayed, keeping evidence of correction and withdrawal as well as initial approval. A material source change reopens target-language, subject, accessibility and claim checks; a platform-term change reopens access, data, security and commercial decisions. Publication stays on hold until the named reviewers accept evidence within their own responsibilities.