How to build a local SEO disclosure policy

What to take away

The rest of this guide sets out how to assemble that record.

Name the source for every claim

A disclosure policy answers one question: where a claim came from.

If a page says a client gained 40 per cent more enquiries, the policy should name the source: client analytics, a third-party tool or an estimate.

Our local SEO advertising rules, data and sources guide explains the wider advertising evidence rules.

Assign one owner and a deputy

Name one person who maintains the register. A policy with no owner decays within a quarter. The owner checks that every published figure has a source line, and that the source still loads. Handovers should include the register, not just the login details.

Name a deputy who can check the register when the owner is away.

Build the source register

For local SEO services, the policy covers ranking positions, review counts, footfall figures and case-study results. Use a simple table with one row per claim. Columns: claim, source name, URL, date accessed, reviewer. Add next review date and keep it with client files for an audit trail if a regulator or client asks.

The row below is an illustrative example.

Turn the register into a policy staff can follow. Use this copyable template for each published claim:

Policy rule: do not publish a claim until its source, supporting evidence, disclosure and owner are recorded. Assign a review date and correct materially wrong published claims visibly, keeping the change log.

For guidance on what digital marketing claims must satisfy, the ASA resource library is the practical starting point for CAP code interpretation.

Set review intervals

Not every claim needs the same cycle: a published ranking figure can change weekly; a regulatory citation changes only when the rule changes.

Set the interval when you log the row; let the owner flag anything overdue.

A team reviewing 120 claims might set 30-day checks on performance figures and 12-month checks on legal citations; that split keeps effort proportionate.

Decide what gets disclosed

Disclose the method behind any comparative claim. If you say a page outranks a competitor, give the location, device type and the date you measured. If you quote a review score, name the platform and the date captured, and label any estimated figure as an estimate.

Make paid placements and affiliate content clearly identifiable as advertising where the commercial intent is not obvious; an upfront “Ad” label is a clear way to do that. For review counts, scores and testimonials, record the platform or source, capture date, method, incentives and any relevant relationship. Check platform review policies and the fake-review provisions of the Digital Markets, Competition and Consumers Act 2024; do not publish or commission fake reviews.

Agencies can paste this sentence on a results or case-study page: 'This page reports results for [client] from [start date] to [end date]. The source is [client analytics export or tool name], accessed on [date]. The reviewer is [name], and the next review is [date].'

Publish the policy at a stable URL linked from the site footer and from a footnote on each case-study or results page. Version it with a date and a short version number, for example 'Disclosure policy, version 2.1, 5 June 2025'. Keep the change log beside the register.

For personal data used in audience work, check the ICO advice and services page before you build the register fields.

When the register involves personal data, apply the UK GDPR and Data Protection Act 2018. Record the relevant purpose, lawful basis and retention and access controls in the appropriate internal record, and keep identifiable client or audience data out of a public policy. The Information Commissioner's Office (ICO) says businesses, organisations and sole traders processing personal data must pay its data protection fee unless exempt; record whether that requirement applies.

Record the evidence trail

Save a copy of each source page as a PDF or archive link. Note the date you saved it. If a source later changes, the archived version shows what you relied on. This matters most for regulator guidance, which is updated without notice. Keep the archive alongside the register, with the same row reference.

Handle corrections

When a claim is wrong, correct it in public and log the correction. Record what changed, when, and who approved it. Do not quietly delete a page.

A visible correction builds more trust than a silent edit. It gives the owner a defensible record if a complaint arrives. For wider context, see our UK local SEO rules and compliance guide.

Score the policy

Use this rubric to assess a draft before it goes live. Score each row from 1 to 5, where 5 is fully evidenced.

A total below 25 out of 35 means the policy is not yet auditable.

Escalate legal questions

A disclosure policy is general guidance, not legal advice. Competition, data protection and consumer law questions need a qualified adviser who can review your specific facts. If you see a market problem that affects competitors broadly, report it to the Competition and Markets Authority (CMA) using its market-problem route.

Common questions

Does a small agency need a written policy?

Yes, if it publishes performance claims or handles client data. A one-page register with named sources and dates is enough to start, and it scales as the client list grows.

How often should the register be reviewed?

Set intervals per row. Performance claims might need monthly checks, while regulatory citations can sit for a year unless the underlying rule changes.

What happens if a source link breaks?

Replace it with a current equivalent and note the change in the correction log. The archived copy shows what you originally relied on.

Can the policy be shared with clients?

Yes, and it often helps. A client who can see the source behind each claim is less likely to dispute the reporting later.