Being Everything: PR Won't Find Answers For Petraeus

The most recent sex scandal to shake up government was General David Petraeus. And this story, like many that have come before it, has some public relations professionals asking questions. Specifically, they wonder if the time has come to rewrite the public relations rules for sex scandals.

Not everyone thinks so. Some people are starting to wonder whether public relations professionals are biting off more than they can chew to become de facto organizational ethics coaches. As James Savage points out in his guest post on Communication Ammo, reputation management might not even be within the purvue of public relations.

As Savage quotes risk management expert Dr. Thomas Kaiser: "The role of PR department is essential for 'clean-up' operations following a reputational risk (sic) event, but they should not be key in its active management. Reputational risk is not a PR exercise — the underlying problems of any event need to be solved rather than actively managed after the event."

Kaiser is mostly right. Public relations professionals might face certain risks associated with their field, but they aren't in the business of risk management. However, I do think it is within the purview of public relations to predict consequences, thereby providing counsel to organizational leaders and implementing a plan to serve the organization and public interest.

As noted before, there is a very clear difference between disaster planning and managing public relations related to disaster planning. While some public relations professionals might be knowledgeable enough to address ethics, reputation and disaster management, the doing is different than the talking. When it comes to Petraeus specifically, there is another question that needs to be asked.

Who does the public relations professional serve again?

If public relations is serving the organization and public interest, there isn't much to be done about Gen. Petraeus. To date, in fact, I have never read a definition of public relations that suggested they serve the organization, public interest, and anyone within the organization that has a lapse of good judgement or character flaw.

Other than ensuring the public that there was no breach in security or mitigating any damage because there was a breach in security, the CIA (while perhaps embarrassed) doesn't owe anything to their former head. He obviously wasn't representing the agency when he engaged in the private affair.

In other words, Gen. Petraeus, not public relations, will have to mitigate his own wrongdoings. And even if he did hire a public relations practitioner to communicate this mitigation, they might offer insight into how the public might respond to any specific actions. Otherwise, that's about it.

Sure, there are times when a public relations professional might be called in some time after a mess has occurred but before it is broken to the public. But the ethical viewpoint is pretty clear, especially because public relations professionals do not have attorney-client privilege.

Ethics isn't confined to a single profession. It's for everyone.

When someone brings something wrong to your attention, you tell them it is wrong, refuse to participate or aid in covering up the wrongdoing, and demand immediate correction. Unless public safety is at risk, it is usually advised that the wrongdoer is given the opportunity to correct it on their own, with the understanding that the person they have attempted to being into their confidence will move to correct the problem if the wrongdoer does not. That's not public relations. It's ethics.

I might add that Brad Phillips is right about one thing. The pat crisis plan for sex scandals has worn thin. The public is growing weary of the "admit it, apologize for it, demonstrate remorse, and promise to never do it again" battle plan. That only works for the individual.

As Phillips points out, Newt Gingrich had a better answer. I don't mean it's something to duplicate. I only mean it was true for Gingrich. So maybe that is the best lesson at all. You have to be true to yourself before you can be true to others.

Telling Lies: Ryan Holiday, PR, And Media Today

This isn't a book review, and I don't intend to write one. I have another book I'd rather review next week.

Even so, the topic surrounding Ryan Holiday as he promotes his new book is sending shivers across the public relations industry. Why? Because Holiday embraced what are known as the dark arts of publicity and is now being mislabeled as a public relations celebrity. He's a media manipulator.

In sum, he accomplished his objectives with lies. And now he intends to wear it all like a badge of honor, kind of like someone might take pride in a shiner after a bar fight they started. I beat you, he might smile. Other people might go to jail.

Anyway, some respected public relations professionals are rightly concerned. But they ought not be concerned with how this paints the industry. They ought to be concerned about what it could do to public relations.

The worst thing about Holiday's book is some people will treat it like permission. 

There are many companies who would like nothing better than having a propaganda agent on board. Who cares, they say, as long as it spreads. When the game is attention, they think it means gain. But really, it doesn't.

Part of Holiday's credentials include working on the first film with Tucker Max. The movie made $1.4 million and Tucker blamed the failure on the movie's marketing, despite all the pre-buzz controversy. How bad did it fail? It cost $7 million to make.

Another brand Holiday leverages is American Apparel, which also has a pretense for controversy. It is struggling to keep the doors open. The company lost $39.3 million last year; it lost $86.3 million in 2010.

It might not even matter that Holiday claims that being a media manipulator left him morally bankrupt. Some will skip over the lesson and get to work. And there may be reason to doubt that Holiday is done with the so-called skill set. His book could be easily construed as his latest game. The PR/blogging community is primed to stoke the flames and feed the beast.

Holiday's book as continuation after the confession and the joke's on you. 

As people in public relations and media continue to react, Holiday could be sitting back with a smile as he beats the same dead horse he wrote about. He laid out the foundation for controversy and everyone is lining up to ratchet it up and do all the leg work. They write about it. People buy it.

Isn't that ultimately what the book is about? The general idea is that more spin equals more attention and more attention means more money. This hypothesis has been around since the circus, even if the old adage that all publicity is good publicity is merely a hat trick. All publicity is good publicity, but only if you happen to be in a circus and nobody gets physically hurt (most of the time).

That said, Holiday isn't the first to sound the alarm on media manipulation and he won't be the last. He is the latest to be a bit cavalier about it, but that is a sign of the times. The real lesson here is that objective journalism is mostly dead and probably will be until we suffer a disaster for our lack of it.

That was pretty much the conclusion I had after reviewing Bob Conrad's book on the same topic. What a shame more PR pros didn't cover that one. Conrad's case studies hit harder and he didn't need to lie.

Suffice to say that sooner or later, people will have to realize on their own that the art of online influence is idiocy and the news you read isn't worth beans if it is driven by popular opinion.

As for Holiday, it is not my place to judge him. The only apparent tell in his actions is that he has done a fine job employing the apology clause tucked inside most pat crisis communication plans. But ultimately, he still proves himself a bit of a novice because he omits the critical component of restitution.

If he was sincere, he would donate all his book proceeds to fix it. I don't think that is going to happen.

Applying Ethics: Penn State Is Not A PR Story

Bill Sledzik is right. The Penn State scandal is not really a public relations case study. It can't be "fixed." The only thing left to do is continue to cooperate with transparency and suggest remedies to minimize such atrocities from happening again.

Attorney General Linda Kelly described it precisely: "This is a case about a sexual predator who used his position within the university and community to repeatedly prey on young boys. It is also a case of high-ranking university officials who allegedly failed to report the sexual assault of a young boy after the information was brought to their attention, and later made false statements to a grand jury that was investigating a series of assaults on young boys."

Any potential for this case to remain within the sphere of public relations ended in 2002. And even then, the only thing that could be done would have been to advise that the incident be immediately brought to the attention of the police regardless of potential public relations fallout. That was almost 10 years ago.

There are two worthwhile discussion points: understanding ethics and bystander psychology. 

Neither Mike McQuery, who witnessed the child rape firsthand, nor head football coach Joe Paterno should have been satisfied with the decisions reportedly made by then athletic director Tim Curley or senior vice president for finance and business Gary Schulz (who also oversaw campus police).

The ethical course for McQuery is clear. He should have intervened. Or if he felt the intervention put his life at risk, he should have immediately called the police. Instead, he reportedly turned to an authority figure, his father, and subsequently Paterno. While the behavior is understandable from a psychological viewpoint, it doesn't make it right. Personal, moral, and ethical responsibility cannot be so simply surrendered by a bystander to higher authorities, even at the risk of an early career.

Likewise, the same applies to Paterno. Once it was brought to his attention, there ought to have been no question of how to proceed. While notifying Curley and indirectly Schulz of the situation would have been acceptable, the only personal, moral, and ethical course would be to report the incident to police or insist that Curley and Schulz do so.

They did not. Instead, Curley and Schulz made the wrong decision when it was brought to their attention, apparently to keep the incident from going public while trying to distance the school from future liability in the event Arthur "Jerry" Sandusky was caught again. Eventually, when the incident surfaced during testimony, concern for public exposure quickly turned to protecting themselves from criminal liability, as it often does.

If the crime did not involve the public safety of a victim (such as lying to the media about something more trivial), then the appropriate course of action could have been to confront the wrongdoer and give them an opportunity to come forward and correct their mistake (and reporting it only if they are unwilling to do so). But any time there is an immediate threat to the public safety of one or more people, there is no obligation to grant the wrongdoer any such courtesy. You stop it. You report it.

What public relations professionals need to know about the Penn State scandal.

It is not uncommon for public relations professionals, especially those in the early stages of their careers, to be asked to lie, spin, or exaggerate on behalf of companies. And, more commonly, some will attempt to exempt themselves from responsibility after passing information to an authority figure. Don't do it.

If this case can teach students anything, it is that attempting to cover up an atrocity (regardless of size) doesn't protect anyone. It only makes everyone who knows liable for a lifetime and anyone who doesn't know another potential victim. And yes, once you know, the suffering of those victims falls squarely on your shoulders, as rightly conveyed by Attorney General Kelly.

"The failure of top university officials to act on reports of Sandusky's alleged sexual misconduct, even after it was reported to them in graphic detail by an eyewitness, allowed the predator to walk free for years - continuing to target new victims," Kelly said. "Equally disturbing is the lack of action and apparent lack of concern among those same officials, and others who received information about this case, who either avoided asking difficult questions or chose to look the other way."

Partial source: grand jury presentment, Pennsylvania Office of the Attorney General.

Gaming Apologies: Empty Without Empathy

Last year, Bob Conrad was one of a few communicators who stood in defense of Toyota while it was savaged in media coverage over recalls. This year, ample evidence has been released that demonstrates Toyota was essentially proven to not be at fault for the accidents.

I was less sympathetic, but only because Toyota made the decision to apologize too quickly. It had come before Toyota had even identified the problem.

Why? They assumed their own guilt because of a rushed and improper situation analysis. Once they apologized and accepted guilt, nobody was ready to believe them again, at least not right away.

Taco Bell isn't handing out apologies. They're handing out tacos.

In the wake of a lawsuit claiming that Taco Bell is misleading consumers into believing it serves "seasoned ground beef" as opposed to "taco meat filling," dozens were prompted to make jokes and try to turn allegations into opportunity at the expense of the chain.

Had the company employed the ten commandments of social media crisis management, they would have rushed in, taken their lumps, and said they were sorry. So why didn't they?


Personally, I'm not a fan of fast food but I have to give them props. They paused long enough to conduct a situation analysis and conclude they aren't guilty. Their taco filling contains considerably more beef (88 percent) than the plaintiffs want people to believe (35-36 percent). The courts will decide the rest, but the public crisis appears to have been abated.

Most apologies are meaningless anyway.

Perhaps worse than not offering an apology when it is warranted is offering one that doesn't sound like much of an apology. Ask Nir Rosen.

He had every reason to apologize after some of the mean-spirited remarks he made related to the Lara Logan atrocity. And he did apologize, sort of, maybe not.

"There's probably some larger lesson about social media to be drawn here, and how its immediacy can be great in its power to connect us," Rosen wrote. "But also a liability because something blurted out and not meant to be serious acquires a greater power."

Um, hardly. There is no larger lesson about the immediacy of social media to be learned from Rosen or how things might be taken out of context. There is, however, a lesson that can be drawn from his article. It appears to be the one quality he seems to lack.

Empathy is the most important aspect of an apology.

It's simple. Apologies are meant to be an expression of empathy from the guilty. And, when they are well meant, they might elicit forgiveness. But without empathy, they're empty words — a ploy concocted by public relations and propaganda.

Some public relations professionals advise that apologies are critical to protecting reputation, guilty or not. However, if they are delivered with a lack of empathy, it reveals something worse than no apology at all.

For Toyota, it showed how willing their executives were to trade strength of character for the illusion of reputation. And, for Rosen, it seem obvious that he is only ready to apologize for the damage he caused himself.

In fact, both of them might have fared better with non-apologetic empathy. For example, Toyota executives could have expressed their sympathy for any accident victims and their families while investigating the claims (perhaps offering to help even if they were not at fault). Or, perhaps Rosen could have reflected on how his words could have made sexual assault victims and women feel instead of intellectualizing his dilemma in an article.

And when no one was hurt? Taco Bell might have made the right play. Most people seem to be expressing empathy for them these days. That makes sense. Besides, their tacos only contain one-and-a-half ounces of seasoned beef anyway.

Setting Example: How Ethics Plays Out, And Pays Out

While I would never encourage someone to seek a position to be a whistleblower, Cheryl Eckard, the former global quality assurance manager of GlaxoSmithKline (GSK), demonstrated a near perfect example of how ethics ought to play out.

It's a lesson more public relations professionals and communicators might learn. As an industry, I sense many are still struggling to get it right. Well, it's more than a sense. I see exams that demonstrate ethics is approaching a crisis stage.

Eckard received $96 million of the settlement paid by the London-based company, which included $150 million in criminal fines and $600 million in civil penalties. The entire story makes an interesting case study in public relations. But for the purposes of the this post, the best lesson is how to approach ethical dilemmas inside a company.

How Eckard Approached Ethics Inside GlaxoSmithKline.

1. Eckard went to the Puerto Rico plant in August 2002 to correct manufacturing violations.
2. She discovered numerous violations, and suggested how those violations might be fixed.
3. She reported the problems to her superiors and the company's compliance department.
4. According to reports, neither the company nor the plant did anything to address the problems.
5. Eckard was eventually terminated, one year later, allegedly because of continuing to report problems.
6. Eckard turned whistleblower out of concern for consumer safety and public health.

The only area for improvement, keeping in mind it isn't clear if the company fired her prior to her realizing the company did not intend to take action, is Eckard could have resigned and still turned whistleblower. Any member of any company has an obligation to warn the public when all efforts to correct a problem internally have failed.

"We regret that we operated the Cidra facility in a manner that was inconsistent with current Good Manufacturing Practice (cGMP) requirements and with GSK's commitment to manufacturing quality," said PD Villarreal, senior vice president and head of global litigation. "GSK worked hard to resolve fully the manufacturing issues at the Cidra facility prior to its closure in 2009 and we are committed to continuous improvement in our manufacturing processes."

Most reports indicate the plant was in violation of safety standards through 2005. The settlement statement reinforces that the company has not received any additional FDA warning letters since 2005. The plant continued to operate until 2009.

Where Public Relations Professionals And Communicators Tend To Trip Up.

From what I have noted, public relations professionals and communicators tend to fall on the opposite extremes of ethics. Either they pounce, reporting and making public any problems (even if there are none) without giving anyone the opportunity to do the right thing. Or, they don't go far enough, following most steps correctly until it becomes time to resign.

Only about 50 percent say they would be prepared to resign. Only about two percent say they would go public after resigning, potentially allowing public safety problems to occur. This concerns me. It ought to concern you too.

While situations might call for variations, ethical dilemmas are best handled by raising the issue with the guilty party, allowing them to correct the mistake and report the problem on their own. If they do not, then the discovering party should report it up to supervisors until one of them takes action. If no one is willing to, then the next appropriate step is to resign, letting the company know you intend to go public. What else is there?

Frustrating Employees: American Airlines

It only took an hour for American Airlines to find and terminate Mr. X, a UX user experience architect working for the company, after he responded to a Web site critique offered up by Dustin Curtis, a designer who creates user interfaces and experiences.

"The problem with the design of AA.com, however, lies less in our competency (or lack thereof, as you pointed out in your post) and more with the culture and processes employed here at American Airlines." — Mr. X

In reading through more than 150 comments left on Curtis' post, I couldn't help but wonder about the confusion. Some people said the firing was warranted. Others said it was another example of the company's incompetence. Some said that it was somehow Curtis' fault. Very few seemed to find the truth. What's that?

Two wrongs don't make a right, they make a mess.

1. We can remove Curtis from the equation. He didn't do anything wrong in offering a public pitch. In a world where many people with experience and expertise can become a content publisher, companies and their employees have to expect and accept both praise and criticism. The only question: How will the company choose to respond or react to the communication?

If any company operating in the 21st century hasn't answered this question by now, they are inviting, even encouraging, crisis.

2. It is always unfortunate when someone is terminated over carelessness because they care. However, Mr. X clearly violated one of the most basic ethical tenants. Aside from American Airlines' non-disclosure agreement, it is generally understood that communicators protect confidential information and, at the same time, comply with all legal requirements for the disclosure of information affecting the welfare of others.

If Mr. X truly cared about the company, his response to Curtis would have been better sent to his supervisor to affect change.

3. Appreciating that there may be other grounds for termination that we may be not aware of, American Airlines demonstrates they clearly have an international communication problem. When employees feel more comfortable confiding about their experience to external sources of information over internal channels because they feel powerless to be the catalyst for positive change, then that is a problem. And now, it's a public problem with a greater consequence than any breach of non-disclosure.

American Airlines has to know it has flaws in its communication strategy given that everyone else does. A warning might have been enough.

Companies need to develop clear and concise response guidelines.

Without a more comprehensive understanding of American Airlines internal communication components, there isn't much we can do. However, it does seem clear that they need to develop clear and concise online response guidelines. Here are a few:

• Define who will respond and under what circumstances.
• Respond in a timely manner when the topic is still hot.
• Read the greater body of ongoing work to ensure you understand it.
• Recognize who the person, people, or media might be before you respond.
• Remain positive, reasoned, and focus on clarifications (unless your brand is satirical).
• Stay focused on the topic if you hope to maintain credibility, authenticity, and transparency.
• Recognize that engagement is a limited commitment, which may require a follow-up response.

Imagine how even a handful of points might have made a difference at American Airlines. Mr. X would have been allowed to respond as himself or known to forward any notes along to a supervisor. The authorized representative could have responded, possibly generating goodwill for American Airlines. Or maybe not, since the original post was obviously a public pitch.

The psychology of criticism and the art of the pause.

There isn't a tremendous body of worthwhile research revolving around the study of criticism and how people respond to it. Most people simply respond to it badly. Generally, it is because they tend to react as opposed to respond, which is why media relations training has a tendency to focus on the trappings of pointed questions.

Professionally, I try to teach people to accept criticism, provided it isn't cynicism. As I've proposed before, critics strive to be open, objective, and offer suggestions for improvement or make an effort to understand various points of view. Cynics are generally closed, biased, and reject that any merit exists or tend to promote their point of view while dismissing the validity of any other.

As a general rule of thumb, people are almost always better served by pausing anytime they feel an immediate emotional response to any particular comment. The pause allows us to process the information and ascertain intent.

Teachers, for example, are paid to provide constructive criticism. Managers are charged with evaluating performance. And the best reporters always ask tough questions to find the truth. Some bloggers too, employ criticism as a means of driving conversations forward.

In all of these cases, the intent is grounded in compassion for education, employee, public welfare, or special interest. We ought not to shy away from it, but embrace it. You don't have to accept every idea as valid, but critics often lend a few gems.

Managing Upturns: Reactionary Expectations

"Those who succeed will be ones that focused on fundamental issues as the financial crisis and the recession intensified. If competitors are cutting back advertising or cutting their sales force, now is the time to increase or maintain them." — Yoram (Jerry) Wind, a professor of marketing at Wharton University of Pennsylvania

Two weeks ago, I met with an executive who had decided a little bit of publicity could go a long way for her struggling business. A well-placed feature release, she concluded, would make all the difference.

Could it really?

In evaluating the business there seemed to be more nostalgia than newsworthy forward motion. So while a feature release on the company's past position and links to history might have made an interesting story to someone, it seemed far enough off from the company's business objectives that we made a different recommendation for approximately the same investment, but with an ongoing communication program.

While she thought the program was perfect, she passed. Perhaps when the economy shows more signs of an economic upturn, she said. We'll wait until we see increases in revenue. Right now, she said, our expectations are low.

“The greater danger for most of us lies not in setting our aim too high and falling short; but in setting our aim too low, and achieving our mark.” — Michelangelo

While some companies are already noting that the best six-month run on Wall Street might be revealing an increase in consumer confidence, there are an equal number of companies and organizations that have tied their success to outside forces, especially the economy. A recent article featured by Knowledge@Wharton seems to suggest that even with an economic upturn, low expectations are the way to go.

It's a message that seems to resonate with employees. Watson Wyatt released a study today that reveals cost-cutting actions that employers have been making to deal with the economic crisis have contributed to a sharp decline in the morale and commitment of their workers, especially top performers. And, according to some key findings, everyone's expectations are already low:

• While organizations have been making major changes, employee engagement has dropped 9 percent since last year for all employees and close to 25 percent for top-performing employees.

• Top-performing employees are 20 percent less likely to agree that they understand the link between their own goals and the company’s goals than in 2008.

• Forty-one percent of employees indicate that changes have had an adverse impact on quality and customer service, while only 17 percent of employers believe this is the case.

“There is no scarcity of opportunity to make a living at what you love; there's only scarcity of resolve to make it happen.” — Wayne Dyer

There are two ways to view economic indicators and the environments in which businesses operate. The first is to view a company as reliant on the economic climate. The second is to discover opportunities within those environments.

The former group of companies are operating on the pretense that they need to protect what they have. The latter group of companies appreciates that they never had anything except what they innovated and earned.

The former group saw revenues decline, as their strategists predicted. The latter saw revenues increase, despite the recession.

What's the difference? Operating from a viewpoint of scarcity usually creates more of the same, with longer term consequences. Or, in other words, the executive I met with two weeks ago will not likely see an increase in revenue any time in the near future. The best she can hope for is that her competitors feel the same way.

Sure, it would have been easier to rehash her company's history in a feature release with no outcomes (or none that aligned with her business objectives) and then send an invoice for the effort. But sometimes accepting the wrong work for the sake of accepting it seems to me to be a different kind of scarcity that sends the wrong message to our team. After all, we're in the business of helping companies grow. We're not in the business of helping them decline. How about you?

Impacting Everyone: FTC Aims To Regulate

According to Dow Jones Newswires, Lifestyle Lift released a statement yesterday that any complaints were related to the period before the current management team took over and that Lifestyle Lift “regrets that earlier third-party Web site content did not always properly reflect and acknowledge patient comments or indicate that the content was provided by Lifestyle Lift.”

The statement was attributed Gordon Quick, president. We can then only assume that Quick, who became president in February 2008 after working as a executive consultant and mentor, isn't aware of dozens of Web sites created on behalf of the company, including Dr. David M. Kent's Lifestyle Lift Fact, which attributes the cause of complaints to patients with unrealistic expectations and astroturfing by competitors.

"The Internet is filled with misperceptions perpetuated by companies that call themselves 'real this' or 'real that', diaries and 'scams.com' of all sorts," it reads. "Lifestyle Lift is not the only firm being targeted by these unscrupulous websites that profit from sensationalism and hype."

"In the past at Lifestyle Lift, we have had a small number of patients who elected a procedure for the wrong reasons. These patients, although they have no medical problems, tarnish the image of Lifestyle Lift and our Doctors on the Internet," another section reads. "These unhappy patients will often complain of long recovery times, no change in their appearance,'scar for no reason', pain, missed work, unhappiness, scarring, 'no one cares', 'no one noticed me' etc."

The publication date is 2008. Most other sites that look as if they are patient generated (except for disclaimers) were also published in or after 2008.

How It Affects People Beyond Cosmetic Surgery

Lifestyle Lift isn't indicative of all cosmetic surgery or all social media. However, it's fair to assume their online approach sets the tone of the Federal Trade Commission, which has proposed new rules that could take affect this summer.

Most of the changes are harmless. Bloggers would be asked to disclose any relationship they have with a sponsor, any compensation received for a specific post, and whether the product they received was free. All of these changes follow standard ethical guidelines observed by most social media participants.

The one change that might not be harmless, as described by Ragan.com, is bloggers would be held liable for making false or unsubstantiated claims about products. Companies paying bloggers could be held liable too.

The policies would not be exclusive to cosmetic surgery or anonymous posts by executives, but everyone who endorses businesses and plays video games. Unfortunately, regulation of the Internet is problematic, potentially infringing on free speech and censoring honest opinions (good and bad).

Fortunately, the Federal Trade Commission is still seeking public comment. You can find those guidelines here.

Several Stories Related Astroturf And The FTC

"FTC Launches First Wave Of Smackdown On Scammy Loan Consultants" by Chris Walters, The Consumerist

"The Plaintiffs’ Bar’s Covert Effort To Expand State Attorney General Federal Enforcement Power" by Victor E. Schwartz and Christopher E. Appel, Washington Legal Foundation

"TripAdvisor Warns Of Hotels Posting Fake Reviews" by Melissa Trujillo, The Associated Press

Paying Fines: Lifestyle Lift

According to The New York Times, Lifestyle Lift, a national cosmetic surgery company with 80 doctors working in offices spread across the U.S., settled with the State of New York over its attempts to fake positive consumer reviews on the Web. The company will pay $300,000 in penalties and costs to the state.

An "attempt to generate business by duping consumers was cynical, manipulative and illegal,” Andrew M. Cuomo, New York’s attorney general told The New York Times.

The $300,000 in penalties and fines will likely be the least of the company's damages. If the Mich.-based company felt negative reviews hurt its reputation as reported, the damage caused by fake reviews will become a blemish that will be hard to overcome.

Adding insult to self-inflicted injury, the attorney general’s office shared one e-mail that instructed employees to "devote the day to doing more postings on the Web as a satisfied client.” Thomas Seery, founder of RealSelf.com, where Lifestyle Lift has more than 18o negative reviews, called it right when he said "It’s an incredible violation of consumer trust and it’s a pernicious element of the Web that some companies have embraced this idea, under the guise of reputation management.”

Make no mistake, writing a fake review is not reputation management, especially from a company that carries a "Truth In Medicine" paragraph on its Website. It also pledged that "all Internet communications accompanied by the trademarked Lifestyle Lift logo are fair and accurately represent the latest in medical information about facial firming procedures."

Faking The Net Is No Way To Manage Communication

When a company is bombarded with hundreds of negative reviews, the temptation to fake reviews might be overwhelming.

It's especially true when some reviews include comments such as "I am getting depressed and worry about looking like a freak forever," "My scars are not so bad, but my sister's scars seem to move away from the ear line to the center of her cheek as time goes by," and "My mother has horrible scars from this & her ears are numb. She also has severe pain, constant pain." All of them include procedural costs that ranged from $1,500 to $8,000.

And while the Website claims "satisfying clients has led to unparalleled growth," a simple Google search seems to reveal a different explanation all together. Websites and/or affiliate program sites here, here, here, and here seem to be the sad secret to the its success. Assuming what seems like dozens of sites will eventually be removed, you can read more reviews uncovered by the Consumer Alert Report here.

The fallout doesn't seem to be limited to the practice. The Post-Standard included a local angle that alleges "Dr. Douglas W. Halliday, an ear nose and throat doctor with an office at 4939 Brittonfield Parkway, is listed on Lifestyle Lift's Web site as one of its physicians. Earlier this year, the state fined Halliday $20,000 after he was accused of injecting patients with an unapproved drug he told them was Botox."

When you add up all the damage done to this company in the months ahead, the original reviews and $300,000 fine will be miniscule when compared to the local journalist and consumer investigations of its doctors, more women with problems come forward to share their stories, other AG offices consider launching their own investigations, and a mostly unforgiving online public weighs in on what it thinks of astroturf.

Considering Lifestyle Lift doesn't seem to have any semblance of a crisis communication plan in place, we suspect it's a company in trouble. Its story, as once seen on Montel, NBC, ABC, CBS, Fox, and even in an endorsement from David Griffin who appeared as a contestant on The Biggest Loser, will be replaced with another meaning all together.

Survivable? Perhaps a few months ago. Today? It will take a living case study to know.

Selling You On Twitter: uSocial

“We just signed a contract with a large Fortune 500 company who have invested around $22,000 with us to conduct a continuing Twitter marketing campaign. The package includes some custom-designed tactics for them, as well as some services of ours which are publicly available like our Twitter follower packages." — Leon Hill, CEO of uSocial.net

So what is uSocial’s Twitter follower packages? According to the OfficialWire, its suite of Twitter marketing services includes allowing their clients to buy Twitter followers.

Buy Followers?

Right. uSocial claims for an investment of only $87, "we'll bring you 1,000 brand new Twitter followers to your existing account, or we'll set up a new account for yourself or your business at no charge in order to deliver the followers." If you think that is a bargain, 100,000 Twitter followers is $3,479 (normally charged at $4,970), which makes us all cheap. Cheep.

“Our client has requested anonymity, however I can tell you they’re an organization in the health sector,” Hill told OfficialWire. “I wish I could say more, though I have to respect the wishes of my paying customers.”

We're not surprised. Any decision maker willing to purchase Twitter followers is unlikely to be authentic, externally or internally.

Surfing For Survival: The Fourth Estate

"But what if the old media dies much more quickly? What if a hurricane comes along and obliterates the dunes entirely? Specifically, what if The New York Times goes out of business—like, this May?" — Michael Hirschorn, The Atlantic

When The New York Times released an October earnings report that revealed drastic measures must be taken or the paper would be forced to default on $400 million debt, some people, including journalists like Hirschorn, woke up wondering what if what once seemed like a slow a painful death for print might be hastened before they could develop a viable online business migration model. And what would that mean for journalism? And what would that mean for public relations?

The New York Times is not alone. Any time I spoke about social media last year, I carried some disappointing circulation statistics with me — most papers were down double digits: Boston Globe, down 10.1 percent; Philadelphia Inquirer, down 11.0 percent; the Miami Herald, down 11.8 percent; the Detroit News, down 10 percent; the Houston Chronicle, down 11.6 percent. And that says nothing about the Tribune Co. bankruptcy.

A few weeks ago, Thomas Mitchell, editor of the Las Vegas Review-Journal, noted "Information wants to be free, reporters want to be paid" in a column that reminds readers that newspapers survive to provide substance. He's right. Anyone can offer up opinion. Anyone can cater to the masses for link love and pats on the back. But not everyone will "sit through the council meeting and sift through the volumes of bureaucratic paperwork" or be able to disassemble and reassemble it in order to objectively educate the public as to what it means to them.

True enough, as that was the same point Paul Mulshine, opinion columnist for the Newark Star-Ledger, made in the The Wall Street Journal. And I heard similar comments while sitting on a panel with Bruce Spotleson, group publisher at Greenspun Media; Jon Ralston, columnist and commentator on state politics, and Flo Rogers, general manager of Southern Nevada's KNPR. Increasingly, the public seems more interested in news that supports their worldview than the last remnants of objective journalism.

Sure, the old model must change. But what newspapers need to remember is they can't wait for someone else to invent it. Most models will be different. Some might shrink print content while driving more readers online for additional content. Some might create online communities for the strongest sections. Some might place a greater emphasis on another medium like video. Some will attempt to give up the one-way new stream and encourage journalists to engage the public, something BusinessWeek seems to be experimenting with, but with mixed reception. And some, well, some will surely just lay down and die. But what if they all did?

Ethics & The Fourth Estate

It's a question I ask myself every year while I prepare to teach public relations skill sets that seem a little less valued today than they were last year or the year before that. Do they even know that the burden of business ethics might fall all the more on their shoulders? That's one question Bill Sledzik, associate professor in the School of Journalism & Mass Communication at Kent State University, has on his mind as well.

"I worry that too many PR types will place client interest ahead of public interest, expediency ahead of ethics," he writes. "They have in the past, and social media makes it that much easier today."

He might be right to worry. Even where there aren't ethical lapses, the slips seem more frequent (even among those who profess transparency). There are a few who already seem all too comfortable walking right up to the ethical line (if not crossing it) or redefining it to fit their needs. Even more don't really understand ethics all that well. When I share ethical challenges in a class, for example, the informal fail rate has been as high as 90 percent.

It may get worse before it gets better. A survey recently conducted by the Society of Corporate Compliance and Ethics (SCCE) and the Health Care Compliance Association (HCCA) reveals that the declining economy might increase the risk of legal and ethics violations in business. In fact, more than 85 percent of 600 compliance and business ethics professionals felt that the current economy greatly or somewhat increases the risk of compliance and ethics failures with only one percent offering a contrarian opinion. (The complete survey results can be downloaded here).

"There's good and bad news here," observed Roy Snell, the CEO of SCCE and HCCA. "We're finding that companies are increasingly seeing compliance and ethics as an integral part of their business and not a luxury to be discarded during an economic downturn. But, at the same time, we're seeing stagnant budgets or potential declines in resources at a time of increased risk for failures. That's creating a gap that could prove to be a dangerous chasm for business to cross."

And what if they do cross it? Without a viable Fourth Estate, there may be less risk and consequence. Yesterday, it used to be a suitable ethical review sum up to end with a single quip — unless you would be proud to see what you say or do on the front page of The Wall Street Journal or New York Times, then don't say or do it. Today, you can buy space on the front page instead. And tomorrow, there might not be one to care.

Being Human: Chris Brogan

If there are lessons to be learned from the veracity of a conversation that occurred this weekend around Chris Brogan, president of New Marketing Labs, it might not be what most people think. What began as a question of ethics quickly descended into something else: a not-so-subtle reminder that for all those social media participants who mistrust companies, the people who make up these companies might have cause to not trust social media participants.

And why should they? It's all too easy to deduce that social media participants eat their own.

What began as a relatively harmless sponsored puff piece by Brogan, describing a K-Mart shopping spree like a kid in a candy store, ended in charges that Brogan might never be trusted again.

Initially, it seemed like an excellent ethics discussion, but then it morphed into what some people might describe as a French mob. Then it morphed into a civil war (given that people seemed evenly split). And then again, it morphed into a 'reverse' French mob against Damien Basile (among others), a senior associate editor for CritqueMedia.com, because he was as outspoken as Brogan was sometimes defensive. If you get the sense it was a mess, you might be right.

The initial conversation seemed promising enough.

On the forefront of the conversation, it was just a review by Forrester's Jeremiah Owyang: "Transparent, Yes. Authentic? Debatable. Sustainable? No." (Hat tip: Arron Brazell). And then it was easy to see that there were ethical questions being raised (never mind it was less clear which ethical questions were being raised).

For some, it was whether or not sponsored posts are ethical. For others, it was whether Brogan appropriately disclosed his relationship with Izea, given he also serves on an advisory board. And for others still, it was whether personal relationships and reputation are exempt from ethical review.

The general topic reveals paying for posts is split, but shifting in favor of.

The question of blogger compensation has been around a long time. Last March, there was a survey that touched on the practice, but it was written wrong. However, if you spend enough time speaking with various people, you'll find they are generally split on sponsored posts, with most who find them acceptable adding a condition of disclosure.

Of course, even with disclosure, there are always going to be challenges with sponsored posts. One blogger might accept payments and only write positive posts regardless of how they feel, while another might accept payment and remain perfectly objective. Thus, credibility belongs to the individual and not the practice (usually, hat tip: Owyang).

The conversation might have been better served without being personal.

Brogan's K-Mart post fell in a decidedly gray area. The primary complaint seems to be that Brogan wears many hats. He is generally regarded as a leader in shaping social media, sits on a board of advisors for Izea, and accepted payment from K-Mart through Izea. In addition, Izea wants to run a campaign for K-Mart, using a sponsored post program.

While there were plenty of voices, Basile was one of the more articulate (though sometimes overly passionate and sometimes personal about his principles). Looking back over Basile's comments, it seems to me he was trying to convey that Brogan might not have been a suitable choice for Izea because it is in Brogan's best interest to ensure Izea delivered everything K-Mart hoped it could. In other words, it wasn't the K-Mart post as much as it was his demonstration of Izea delivering puff pieces.

I tend to view ethical questions with IABC's Code of Ethics for Professional Communicators as a guide. Not everyone does, and there are plenty of others to follow. Of the twelve articles that make up IABC's Code of Ethics for Professional Communicators, only one seemed to stand out.

Article 9. Professional communicators do not use confidential information gained as a result of professional activities for personal benefit and do not represent conflicting or competing interests without written consent of those involved.

I asked Brogan if he was paid by K-Mart or Izea. Although he was clear about it in his post, he was a good sport and answered direct. He was paid by Izea. This clarified it for me. Brogan was representing Izea, paid by Izea, and disclosed that arrangement. If you want a contrast, consider Julie Roehm, who accepted gifts from agencies seeking the coveted Wal-Mart account.

Given he wasn't double-dipping, it seems to be less a question of impropriety and more a question about the perception of impropriety. And if we get into the habit of questioning the perception of other people's ethics, we're only disclosing our own lapses of ethical judgment, as Valeria Maltoni so aptly alluded to today.

"Personal experiences have become the new barometer for extrapolating trends. We stopped outsourcing trust to institutions but instead of holding ourselves accountable for our own ethics and behavior, we have shifted that responsibility onto others. Then we cast stones at people we hold up as influentials when we were the ones putting them on the pedestal in the first place."

You cannot be disillusioned by people, unless you're illusioned by them.

Which brings up that other point. While so many people vouched for Brogan's integrity, some of it was done at the expense of others like Basile, who raised valid points. So it's always better to attack issues and not people, knowing someone doesn't preclude them from ethical misconduct. Believing otherwise makes the issue about you and not the subject, invites diatribe that makes discussion look like a popularity contest, and distracts from the most important lessons of all.

"It is error alone which needs the support of government. Truth can stand by itself." — Thomas Jefferson

Sure, Brogan's post changed the perception that some people had of him based on the opening of Julien Smith and his own Trust Economies with a descriptor that reads "We are suspicious of marketing. We don't trust strangers as willingly. Buzz is suspect. It can be bought. Instead, consumers and business people alike are looking towards trust." But did he do something unethical? Not that I can see.

But perhaps more importantly, did the resulting conversations demonstrate a sensitivity to cultural values and beliefs, engaging in fair and balanced communication activities that foster and encourage mutual understanding as IABC advises and many social media participants suggest? Not even close. Trust is fragile, indeed.

Stirring Media Revolutions: Citizen Journalism

"You furnish the pictures and I'll furnish the war." — William Randolph Hearst

With the financial support of his mother, William Randolph Hearst bought the failing New York Journal in 1885. And, within a few short years, his name, along with that of Joseph Pulitzer, who purchased his way into the publishing business (he originally bought the Post for $3,000 and other papers before the New York World), became forever associated with yellow journalism.

Hearst, in particular, was ridiculed and criticized by Upton Sinclair for having newspaper employees who were "willing by deliberate and shameful lies, made out of whole cloth, to stir nations to enmity and drive them to murderous war."

The assertion is linked to the idea that if it had not been for the publishings of Hearst and Pulitzer, there may have never been popular support for U.S. military adventurism in Cuba, Puerto Rico and the Philippines in 1898. But neither Hearst nor Pulitzer were alone in their endeavors to shape the news.

Earlier in American history, it was Alexander Hamilton (1801) who pooled together $10,000 from investors to start the New York Evening Post, specifically to take aim at Thomas Jefferson and the rise in popularity of the Democratic-Republican Party. And, before that, it was newspapers that helped spur on the American Revolution by taking creative license when publishing images such as the famed Boston Massacre. The image, of course, did not represent the facts. The British soldiers were later acquitted for acting in self-defense.

The formalization of objective journalism is a relatively new idea.

These are just some of the historic footnotes I consider every time I hear the term “citizen journalists,” which is generally defined as citizens playing an active role in the process of collecting, reporting, analyzing and disseminating news and information. Most notably, the moniker seems to be assigned to bloggers to suggest that they are somehow they are less than journalists (assuming they even want to be journalists).

Yet, with relative ease it seems, all of those mentioned above — Pulitzer and Hearst and Hamilton and Jefferson — and many others not named — Sam Adams and Benjamin Franklin among them — certainly fit the definition as very actively engaged citizens, without rules, who pursued printing the news as they felt fit.

In fact, Reese Cleghorn, former president of AJR and former dean of the College of Journalism of the University of Maryland, helped put some of this in perspective in 1995. In his article, he leads with how Walter Lippmann commented on "the new objective journalism" and what it might mean for journalism schools in 1931. An excerpt:

"I do not know much about the schools of journalism," Lippman said, "and I cannot say, therefore, whether they are vocational courses designed to teach the unteachable art of the old romantic journalism or professional schools aiming somehow to prepare men for the new objective journalism.

"I suspect, therefore, that schools of journalism in the professional sense will not exist generally until journalism has been practiced for some time as a profession. It has never yet been a profession. It has been at times a dignified calling, at others a romantic adventure, and then again a servile trade.

"But a profession it could not begin to be until modern objective journalism was successfully created, and with it the need of men who consider themselves devoted, as all the professions ideally are, to the service of truth alone."

Think of it for a moment. According to Cleghorn, professional, objective journalism was a mere 64 years old when he wrote his article. And, even then, he was not sure journalism was a profession.

Journalism has always been the art of participating citizens to report.

So it is often with this understanding, I am amused by debates between Michael Tomansky, Guardian America, who suggests that “Journalists relinquish rights frequently in the course of doing their work responsibly, as you well know.” and Jeff Jarvis, BuzzMachine, who counters that “We journalists have long traded in the currencies of access and exclusivity with the powerful. But the price we pay is complicity in a system of secrecy.”

Gentleman, please pause a moment to consider that you are debating a concept that has yet to survive a complete century against another that is less than five years old. So-called professional journalists, those who evolved out of objective journalism, were never meant to be bound by rules, except one, also penned by Lippman.

“There is no higher law in journalism than to tell the truth and shame the devil.”

As one of my journalism professors, Jake Highton, reiterated again in 1978: “Although it has codes of ethics and credos, journalism really has no laws. Yet what Lippman said in the 1920s remains true today: Telling the truth is the highest law of journalism.”

So as unfortunate as it sounds, Jarvis stands correct on those grounds. For a journalist to adhere to a promise of omission for the privilege of inclusion ... well, that strikes me as a promise to not tell the truth.

The division of citizen from journalist ought to be struck from our tongues.

Throughout history, journalists were simply citizens who hoped to make change, with the concept of reporting the truth a secondary consideration in the early 1900s. The only criteria for admission into the field was the cost of a printing press or the ability to knit prose with enough efficiency to be paid by someone who could afford it.

Certainly, social media has lowered the entrance fee considerably, but I propose it has not lowered the bar by any other measure. You see, there have always been journalists who have adhered to and/or relinquished their sense of ethics. But never has there been a code that has withstood the test of time or shackled the profession beyond individual reputation.

Let's face it. Even today, the largest publishers in the world remain tabloids that are willing to publish unsubstantiated fact and fiction at their leisure, sometimes with startling accuracy and other times without a sliver of truth. Should we impose more rules on bloggers than we would the largest publishers in the world? I think not.

And to that end I guess, as important as the conversation might be, what right would any group have to propose such unspoken governance over anyone? Truly, if there are any laws that bloggers might consider, I believe those laws might already be on the books with no other rules necessary.

As professionals continue to discuss the merits of somehow distinguishing the citizen journalist from the professional journalist, I suggest we not tread so heavily to put self-imposed etiquette over free expression. As wiser folks remind us…

“Better a thousandfold abuse of free speech than denial of free speech. The abuse dies in a day, but the denial slays the life of the people, and entombs the hope of the race." — Charles Bradlaugh

Fishing With Prices: Target

Lisa Thurmond, a college student who pens a sometimes funny, often satirical, and always interesting blog Lisa’s World, recently helped popularize a camera-phone picture posted by Michael Wesch, a professor at Kent State University, on Digital Ethnography, a student work group blog.

The picture? A “2 for $4.98” offer on Archer Farms organic flatbread at Target. The price for one? $2.49. He posted it without comment. She called it manipulation.

Both posts garnered some interesting reactions and responses. Some comments zero in on consumer psychology: if it looks like a sale, our brain reacts like it is a sale, even when it isn’t a sale. Others, they called it patently unethical and misleading.

Only one person defended Target by calling it marketing” that all mass merchants are employing. Her comment was quickly voted to the bottom.

Well, technically, posting “2 for $4.98” as an advertised price is not unethical. It would require Target to imply that there is a sale as opposed to the consumer inferring that it is a sale. However, resting on that point is about genuine as attempting to redefine what the definition of “is” really is.

The bottom line for marketers? It doesn’t really matter whether “2 for $4.98” is ethical or not. If your price point offer is irritating customers, being technically right could cost you more than being theoretically wrong.

Playing The Numbers: Endoscopy Center Forgets People

Since the beginning, the Endoscopy Center of Southern Nevada, which is responsible for the largest hepatitis C scare in the history of the country, has communicated a message much like it ran its practice — by the numbers.

Its message is clear. The risk is minimal to 40,000 patients who must be tested for hepatitis C as well as hepatitis B and HIV. Only six patients have been proven to be diagnosed with acute hepatitis C. Except… Except…

We’re not really talking about numbers. We’re talking about people.

Numbers don’t tell stories; people do.

My longtime friend and colleague Keith Sheldon, for example, is not a number. He’s a person. He’s also one of the many who never learned he needed to be tested because of a letter. He learned, like thousands of other patients, through the media.

“I was sitting in bed with my wife reading the Saturday paper,” Sheldon said. “At first, I didn’t think the crisis applied to me.”

It wasn’t until his wife started crying that his initial reaction, things like this happen to other people, didn’t apply. Sheldon was not only at risk, but had unknowingly put his wife at risk. And learning the center was notifying patients by letter and setting up a foundation was little consolation.

“As soon as I learned my health was at risk, I immediately made an appointment with my doctor,” he said. “He saw me the same morning … when it comes to your health, you don’t wait for red tape.”

It didn’t matter to Sheldon that he had to pay out of pocket for the test, despite promises that the center had already made arrangements with various health insurance providers. He needed answers … answers that still haven’t arrived. Because of the number of people being tested, most results will not be made readily available for seven to 10 days, which is next Monday or Tuesday at best.

“I hold the clinic’s management responsible for this disaster,” Sheldon said. “Specifically those individuals who had the day-to-day responsibility and oversight for how business was conducted.”

Recently, one doctor, who was employed at the center and asked the Las Vegas Review-Journal for anonymity because he fears "retaliation" from Dr. Desai (majority owner of the Endoscopy Center of Southern Nevada), said he left the clinic in 2000 — which places the start of the unsafe practices back to more than a decade — because he "was so depressed." He was reprimanded several times, the article says, because he was allegedly pressured to perform unnecessary biopsies, coupled with fabricated lengthy patient examinations, that could add more than $300 to a bill.

"It was so unethical," he said. "I couldn't live with myself."

As more stories surface, it seems to be that the entire practice was built on the concept of placing profits before people. By the account, it was always about playing the numbers: Reusing a single dose vial or the same syringe here and an extra biopsy there, well, it could help the clinic pay the bills.

Sheldon, who also teaches public relations and assists companies in crisis communication situations, is also mortified by the lack of empathy or apology by the center. From a business, ethical, and public relations perspective, the clinic is doing a dismal job of handling this crisis, he said.

“Rather than waste thousands of dollars on a poorly written, ill-conceived and
disingenuous full-page ad in the Review-Journal, the Endoscopy Center should have offered to pay for people to have their blood tested immediately,” he said. “ You just cannot put profit over people.”

When asked how the clinic might have responded, Sheldon offered…

“We demonstrated dismal judgment. We lost track of our mission of taking care of our patients to the best of our ability. We put profits over patients. For these transgressions, we are sorry. We pledge to make full restitution to the degree determined by the courts.”

I wholeheartedly agree. Anytime a company has surrendered all measure of professional efforts, there is nothing left to be done other than offer full disclosure, pledge full restitution, and permanently resign from the medical profession. These are not numbers; they are people — 40,000 people who are slowly learning through the media that they and their families — wives, husbands, sons, daughters — are at risk, one person at a time.

And, worse, it seems more and more clear every day that the numbers like six people infected and 40,000 at minimal risk, are designed to diminish the impact of real people, are growing every day. Dr. Desai ran six number-crunching clinics in southern Nevada. And, it has already become clear that the first clinic only offered a truncated list with 40,000 patients. Many more patients need testing.

For all of them, restitution seems obvious.

• Direct and full compensation for all testing without any fees being passed on to insurance companies.
• Free counseling for patients who are having challenges coping with the situation.
• Compensation for the pain, suffering, and anguish caused to the thousands of people put in harm’s way.
• The maximum amount paid out in medical malpractice to anyone who has to endure a shortened lifespan and risk of infecting loved ones as well as compensation to their families.
• The pledge that none of the management team will ever work in the medical profession again.

These are the only numbers we’re interested in reading about. As for the rest, it’s all about people. People you know and people who may never know if they are infected.

When handling a crisis, always put people first.

Sheldon offers up some hard but true advice for companies that abuse public or employee trust: “Would you have treated members of your family like this?”

The answer, more than likely, would be no. But we can only assume that. Other than the one-page advertisement that claimed patients should still have trust in the clinic, Dr. Desai isn’t talking.

Repeating Milgram: Endoscopy Staff Behavior

In 1963, Stanley Milgram gave the world a glimpse into obedience by publishing the results of his experiment in the Journal of Abnormal and Social Psychology. I learned about the study in college.

The experiment, conducted at Yale University, tested how much pain one participant would inflict on another, provided the participant inflicting the pain would relinquish responsibility to the person they perceived as an authority.

Although the experiment was staged (the person enduring the pain was a actor) and no one was injured, Milgram found that 65 percent of participants would administer an electric shock of what they believed to be 450 volts. Even more surprising, not one participant refused to administer shocks before the 300-volt level, despite several switches clearly marked “danger: severe shock” and the actor complaining of chest pain, banging on the wall, or dropping silent.

With light to moderate prodding, an authority figure in the experiment was able to convince the participant to deliver electric shocks. Some would protest, but continue to “shock” the actor nevertheless.

Understanding Obedient Staff Behavior.

Understanding Milgram’s experiment was followed by strip search prank call several years ago. It was not an experiment. It involved a caller claiming to be the police and instructing fast food managers to strip search employees. In more than 70 reported cases, managers surrendered personal responsibility to an authority figure, becoming like a puppet, and demanded employees remove their clothes.

By comparison, the notion that staff at the Endoscopy Center of Southern Nevada would blindly follow the instruction of administrators to reuse vials of single-dose medicine would likely take less surrendering of responsibility to a higher authority, especially one who had served on the board of the Nevada Board of Medical Examiners.

Why? Proximity to the authority figure. Perceived level of authority. Assurances of a minimal risk. Other nurses already practicing the procedure. And on. And on.

It the only answer for people still wonder why they didn’t stop the practice at the Endoscopy Center of Southern Nevada. Objectivity was sacrificed in favor of perceived acceptance. As one CDC officer reported it: the center’s practices to be so obviously dangerous that it was like “driving the wrong way down the freeway.”

I feel the same way about the center's crisis communication plan. It's like watching a horror show of a horror show, where you watch the next victim stumble up stairs with a flashlight.

The latest update: The Las Vegas Metropolitan Police Department and county prosecutors opened a preliminary criminal investigation. These investigations join inquiries by the FBI and the Nevada attorney general’s office.

Add to all this news an endless stream of sources being tapped by the media, including a very telling and almost incoherent interview with the center’s recently hired third-party crisis expert. Somebody forgot to tell her she wasn't a spokesperson.

Employees Need To Learn To Say No.

Comedian George Carlin includes it in his bit. He says people are too fat and happy to question authority. He's right. It happens all the time.

Even on social networks, it's obvious people blindly follow perceived authority figures, sometimes even participating in a “pile ons” just to be accepted. There is no concern for facts. Most online diatribe can be traced back to obedience and acceptance. It happens everywhere in places all over the world, places just like the Endoscopy Center.

There is only one lesson, and more employees could learn it:

• Th nurses could have complained to the administration that the practices were unsafe, refused to perform them, and demanded correction.
• Upon administrative insistence, the nurses could have told the center to correct its practices or report the incident to county health officials.
• Upon insistence or further inaction, the nurses could have resigned and immediately reported the infractions to county health officials.

Three simple steps could have protected thousands of people from being at risk of hepatitis B, hepatitis C, and HIV. Unfortunately, no one was up to the task. In all the world, only a mere 10-25 percent of people would have been willing to step up to the plate, depending on the country where they were raised.

Skirting Apologies: Endoscopy Center Not So Sorry

On Friday, the Las Vegas Review-Journal reported that the city of Las Vegas shut down the Endoscopy Center of Southern Nevada. After waiting until six patients had completed treatment, all employees were asked to leave the building and the doors were locked.

As mentioned last week, the Endoscopy Center of Southern Nevada was using single dose vials of medication, some of which had become infected with hepatitis C, a potentially fatal blood-borne virus, more than once. Hepatitis C is not the only potential infection that could have been spread; some fear hepatitis B and HIV could have also infected patients, some as far back as 2004 or earlier.

In what appears to be an effort to "control communication," the Endoscopy Center of Southern Nevada, which has declined to comment to any media outlet, did not seem short on words this Sunday. They ran a full-page advertisement in the Las Vegas Review-Journal.

The advertisement, designed to mimic an "open letter to the public" with the headline “Open Letter to Our Patients and the People of Southern Nevada,” smacks as a near-exact carbon copy of an ill-advised communication disaster attempted by Jack in the Box several years ago. Somebody must have missed that case study. It did not work then. It will not work today.

Dr. Dipak Desai offers sympathy but no apology.

“Recent events at the Endoscopy Center of Nevada of Southern Nevada are causing great concern to our patients and the community at large.”

This opening line says it all. It is so obviously written to mask where the responsibility might reside. This was not an accident. The responsibility lands squarely on the medical director and presumed "letter writer" of the advertisement.

In fact, according to the Las Vegas Review-Journal story referenced above, clinic staff has already told health investigators that they knew this technique fell well below accepted medical practices and was dangerous. However, they say they were ordered by administrators to engage in the practice anyway. So they did. The ad continues…

”First, I want to express my deepest sympathy to all our patients and their families for the fear and uncertainly that naturally arises from this situation. The trust we have spent for years building in this community has been challenged by the discovery that some of our patients may have been exposed to blood-borne diseases at our facility. In cooperation with the Southern Nevada Health District and other health agencies and officials, we have carefully reviewed our procedures and implemented the changes they recommended.”

Despite the near admission in the third sentence, there is no direct admission (despite mounting testimony) or any apology whatsoever. Clearly, the aim is an ill-advised attempt to position the crisis as an accident while once again attempting to leverage "trust" that patients placed in the clinic while they were "unknowingly" placed at risk by what seems to be a very "knowing" staff. The ad continues…

“We are also working with third party payers to be sure all our patients who need to be tested are, and that the costs are completely covered.

For those who are uninsured, a foundation is being set up to cover the cost associated with their tests. You will learn more about this in the days to come.”

It amazes me that any company or organization would attempt to promote the argument of denial, despite the fact that the clinic is already proven responsible for the infection of several patients. In addition, the attempt to portray itself as a good public citizen by setting up a foundation reminds me of post-crisis measures employed by Jack In The Box, which they only implemented after sustaining a loss of $20 to $30 million.

The ad continues with another paragraph, first thanking the health district for bringing the problem to the Endoscopy Center of Southern Nevada’s attention and continued clarification that the clinic did not spread the disease to patients one way as has been reported, but another erroneous way all together. As if that matters. The ad closes…

"At the same time and without making excuses, I think it’s important for the public to know that the chances of contracting an infection at our center from 2004 though June 2007 were extremely low. Of the six cases reported, it appears one exposure took place in July 2007 and five on Sept. 21, 2007. Regardless, if you were a patient at our facility, I encourage you to get tested.

Thank you for allowing me to share these thoughts with you.”

The six cases mentioned were those that prompted health officials to conduct an investigation, and not the results of 40,000 tested. Worse, this closure attempts to use the number of confirmed infections as a tool toward exoneration, as if six patients who have been confirmed infected are less significant when compared to the 40,000 that have yet to be tested.

What it also neglects to mention is that health officials are also concerned, however, that even more patients could have been infected prior to 2004 when the clinic operated under a different name. Not everyone is taken by these controlled statements. As expected, one local law firm, Craig P. Kenny & Associates, ran a full-page advertisement in the same section. Its advertisement encourages patients to contact the firm to discuss legal action.

While heroes are seldom found during a crisis, there is one clear hero in Las Vegas. Quest Diagnostics, which is completely unaffiliated with the Endoscopy Center, is the first business to offer to test patients for free. The offer from Quest Diagnostics to provide this community service came after the Endoscopy Center was slow to offer the same and after another health care provider, one that sent overflow patients to the Endoscopy Center, shrugged off any responsibility.

As shocking as it seems, the Endoscopy Center of Southern Nevada has not made any mention of how it intends to compensate those patients who have been infected nor has there been any comment that seems to demonstrate remorse or empathy. So far, it seems they are content to play the numbers and control an uncontrollable message.