Rules and ethics
Part of Why local SEO rules and ethics now decide which agencies win trust
A local SEO disclosure policy needs named sources and review dates
Discover how to build a local SEO disclosure policy that names sources, records review dates and stands up to ASA, ICO and CMA expectations in England.
What to take away
- Decide first who owns the policy, then record the source and date beside every figure, claim or testimonial you publish.
- Name the origin of each statistic: an ONS release, a regulator page or a client's own analytics export.
- Show review dates, so a reader can see when a claim was last checked.
- Keep a copy of the source page, because links move and pages change.
- Treat this as operational paperwork, not a one-off legal exercise.
The rest of this guide sets out how to assemble that record.
Why sources need naming
A disclosure policy answers one question: where did this claim come from? For local SEO services, that covers ranking positions, review counts, footfall figures and case-study results. If a page says a client gained 40 per cent more enquiries, the policy should say whether that came from the client's analytics, a third-party tool or an estimate. The local SEO advertising rules: data and sources article covers the advertising side of that same record.
Start with the owner
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.
Build the source register
Use a simple table. One row per claim. Columns: claim, source name, URL, date accessed, reviewer, next review date. Keep it in the same place as your client files, so an audit trail exists if a regulator or client asks. 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, and let the owner flag anything overdue. Illustrative example: 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, say which location, device type and date you measured. If you quote a review score, name the platform and the date captured. Where a figure is an estimate, label it as one. For personal data used in audience work, check the ICO advice and services page before you build the register fields.
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 turns out to be 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, and it gives the owner a defensible record if a complaint arrives. The local SEO: UK rules and compliance guide for 2027 sets this in the wider regulatory context.
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.
| Criterion | What a 5 looks like |
|---|---|
| Named owner | One person listed with a deputy |
| Source per claim | Every figure has a source name and URL |
| Access dates | Date recorded for each source |
| Review intervals | Interval set per row, not blanket |
| Archive copies | Saved evidence for each cited source |
| Correction log | Public corrections recorded with dates |
| Escalation route | Path to a qualified adviser for legal questions |
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, the route for reporting it is set out on the report a problem to the CMA page.
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.
