Statutory guidance on digital imprints

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Examples of sharing material

The following tables show different examples of ‘chains’ by which material is shared. Each table begins with the same piece of digital material, but in each table it is then republished in a number of different ways.

Chain of sharing organic material where the imprint is included as a part of the material:

Example	Does it require a new imprint? Why?	What they did
A political party tweets an image criticising a rival party’s election manifesto	Yes. It is election material and promoted by a party.	The party includes their imprint in the image itself.
The image is retweeted by one of the party's MPs.	No. It is election material and has been shared by an elected office-holder, but it is exempt under the sharing exemption. It has been shared without being materially altered and the party’s original imprint is still a part of the material.	The MP does not include their own imprint.
A future candidate retweets their colleague's retweet.	No. The sharing exemption still applies – the material is not materially altered and the original party imprint is still a part of the material, so no further imprint is required.	The future candidate does not include their own imprint.

Example

Does it require a new imprint?

Why?

What they did

A political party tweets an image criticising a rival party’s election manifesto

Yes.

It is election material and promoted by a party.

The party includes their imprint in the image itself.

The image is retweeted by one of the party's MPs.

No.

It is election material and has been shared by an elected office-holder, but it is exempt under the sharing exemption. It has been shared without being materially altered and the party’s original imprint is still a part of the material.

The MP does not include their own imprint.

A future candidate retweets their colleague's retweet.

No.

The sharing exemption still applies – the material is not materially altered and the original party imprint is still a part of the material, so no further imprint is required.

The future candidate does not include their own imprint.

Chain of sharing organic material where the imprint is originally in the material but is removed during the republication.

Example	Does it requite a new imprint? Why?	What they did
A political party tweets an image criticising a rival party's election manifesto	Yes. It is election material and promoted by a party.	The party includes their imprint in the image itself.
A registered non-party campaigner screenshots the image and turns it into a Facebook post. They crop the image so that the imprint no longer appears.	Yes. By removing the imprint, they have materially altered the material. This means the sharing exemption does not apply. Because it is election material, and they are a registered campaigner, it requires the campaigner’s imprint under the rules for organic material.	The registered campaigner does not include an imprint, and so commits an offence.
A candidate shared the altered image using the 'Share' button on Facebook.	Yes. The sharing exemption does not apply, because the campaigner in the previous example did not include an imprint.	The candidate must include their own imprint. It is reasonably practicable to include it in the post, so the candidate includes it above the image.
A member of the public shares the same altered image using the 'Share' button on Facebook.	No. Because it is not a paid advert, the imprint rules for organic material only apply to relevant entities. Members of the public who are not a relevant entity, and are not publishing on behalf of one, do not need to include an imprint on organic material, regardless of whether they are publishing it originally or sharing it.	No imprint is required, so the member of the public does not include one.

Chain of sharing organic material where the imprint is included somewhere directly accessible from the material:

Example	Does it require a new imprint? Why?	What they did
A political party tweets an image criticising a rival party's election manifesto.	Yes. It is election material and promoted by a party.	The party includes their imprint in the image itself.
An MP from a rival party republishes the original image using the 'Quote Tweet' function on Twitter. They add a lengthy comment which is critical of the material and the party which originally tweeted the image.	Yes. The MP has shared the material but turned it into election material intended to influence voters to vote against the original party. Because the meaning has been changed, the material has been materially altered. This means that the sharing exemption does not apply. The MP’s tweet is a new piece of material which requires an imprint in its own right.	In this case, because the MP has used up a lot of the character limit with their comment, it is not reasonably practicable to include the imprint as a part of the tweet. The MP therefore adds their own imprint underneath their name in their Twitter bio. This is directly accessible from the tweet because the tweet contains a hyperlink to the bio internal to the platform’s functionality.
A future candidate retweets the MP's tweet.	No. The future candidate’s tweet still contains a hyperlink with a direct link to the MP’s Twitter bio. The imprint is therefore still accessible from the shared material.	The future candidate does not include their own imprint.
An elected mayor screenshots the future candidate's retweet and includes it as part of a TikTok video.	Yes. Because of the way the image has been republished, there is no longer a hyperlink to the MP’s profile, where the original imprint appears. The imprint is no longer accessible from the mayor’s republished material, so the exemption does not apply.	The future candidate therefore includes their own imprint at the start of the video.
A candidate shares the mayor's video by using the stitch feature on TikTok. A section from the end of the mayor's video appears at the start of the candidate's video.	Yes. Because the section of the earlier video that is included does not contain the mayor’s imprint, the material has been materially altered. The sharing exemption does not apply.	The candidate therefore includes an imprint in their video.

Examples where organic material is republished and turned into a paid advert:

Example	Does it require a new imprint? Why?	What they did
A political party tweets an image criticising a rival party's election manifesto.	Yes. It is election material and done by a party.	The party includes their imprint in the image itself.
A campaigner pays Facebook to 'boost' the party's post, thereby turning it into a paid advert.	No. This is now a paid advert, and it is political material. However, the imprint is a part of the original post and is retained. The material has not been materially altered. The sharing exemption applies and the campaigner does not need to include their own imprint.	The campaigner does not include an imprint.
A member of the public creates and publishes a meme criticising a political party and some of their elected office-holders. They do not pay for it to be published as an advert.	No. If material is not published as a paid advert, then an imprint is only required if it is published by or on behalf of a relevant entity. A member of the public is neither one of the relevant entities, nor publishing on behalf of one, and so does not need to display an imprint on organic material.	The member of the public does not include an imprint.
The campaigner pays Facebook to 'boost' the meme, thereby turning it into a paid advert.	Yes. The original meme did not require an imprint because it was not a paid advert and was not posted by a political entity. However, by ‘boosting’ the post, the campaigner has turned it into a paid advert, and it is now political material. Since the original post did not contain an imprint, the campaigner must include their own details in the advert.	The campaigner includes their imprint in the 'disclaimer' section of the advert.

Last updated: 2 November 2023