
Reviews
Part of How to run influencer agencies reviews fairly
Reviewing an influencer agency: seven evidence gates to clear before any verdict
Review an influencer agency in England against seven evidence gates, from identity and advertising to privacy, security and exit, each with its authority.
Scope : The exact agency and service under review, limited to a particular date.
Dossier : The proposal, contract, reference or recorded test result available to the reviewer.
Gate : One evidence question within the review, such as identity or privacy.
Authority : The register, guidance, measure or contract record used to assess evidence at a gate.
Hold : An unresolved result where evidence is absent, not a finding of failure.
Non-compensating : A gate that cannot be cleared by strong evidence at another gate.
Permissioned test : A test carried out with permission, with its results recorded.
Exit : The agreed handling of exports, deletion, rights, payments and account handover.
Fix the boundary before examining evidence
Scope answers which supplier arrangement the decision concerns: the exact agency, service and review date. A trading name alone is too broad. Keep records for another service or an earlier arrangement outside the evidence set, so the finding cannot quietly extend beyond what was actually checked.
The dossier is the material being assessed: proposal, contract, reference or recorded test result. Sort each item against that bounded scope before relying on it. A testimonial selected by the agency remains its claim until the named client confirms it for a comparable service; presentation quality does not change that status.
Ask permissioned clients about a comparable scope and record which statements they confirm. A case study may describe an appealing result, but it is not evidence for every gate. Use the review methodology to keep each finding attached to the named service and date, rather than turning broad impressions into a verdict.
Give every gate its own proof
Treat a gate as one evidence question, not a general impression. The seven checks concern identity, advertising, rights, privacy, security, commercial terms and exit. Authority means the relevant register, guidance, measure or contract record against which the response can be considered.
The evidence map below separates the questions. A record that answers one gate should not be treated as proof at another. The vendor due diligence checklist can help identify records to request, but missing material remains unresolved rather than proving approval or failure.
| Gate | Evidence to request | Authority or measure |
|---|---|---|
| Identity | Registered name, company number, officers and signatory authority | Companies House register |
| Advertising | Briefing, claim support, approval, disclosure, live checking and correction | CMA creator guidance; Digital Markets, Competition and Consumers Act 2024 |
| Rights | Creator work, music, territory, term, media and archive use | GOV.UK copyright guidance |
| Privacy | Purposes, roles, outreach, retention, rights and deletion | ICO controller and processor guidance; PECR |
| Security | Buyer-owned accounts, least privilege, logs and revocation | NCSC social media guidance |
| Commercial | Fees, creator cash, gifts, commission, media and VAT | Written quotes on one brief |
| Exit | Export, deletion, payments and account handover | Contract terms |
The authority provides a reference point, not automatic approval. For example, the Companies House service shows a registered address, incorporation date, and current and resigned company officers at no charge. It does not establish service performance, creator relationships or the payment account.
What clears each gate
A gate clears only when the evidence meets its test below. If the test is not met, the gate stays on hold.
- Identity:the registered name, company number and officers match the contract, invoice and bank details, the company is active, and the signatory is a listed officer or holds written authority.
- Advertising:the agency shows a disclosure policy, a claim approval record and live checking that follow the ASA's CAP Code (rule 2.1 on recognisable ads and Section 3 on misleading claims) and the CMA creator guidance. A sample of live posts carries clear labels.
- Rights:a written grant names the creator work, music, territory, term and media, and the creator or licensor has signed it.
- Privacy:the agency names controller and processor roles, lawful basis, retention and deletion under UK GDPR, and holds a data processing agreement.
- Security:the buyer owns the accounts, two-step verification is on, and access logs exist.
- Commercial:itemised written quotes on one brief show fees, creator cash, gifts, commission, media and VAT.
- Exit:the contract states how data and accounts are returned and deleted.
The permissioned test is a recovery test on a low-risk account: the buyer asks the agency to revoke one user's access and export one campaign's data. The buyer sets the pass marks in advance; for example, access ends within one working day and the export arrives complete within five working days. Record both results with dates.
Keep unresolved evidence in its proper state
Hold is the appropriate result when the dossier contains no proposal, contract, reference or test result. Without evidence there is nothing to mark up or down. This is not a fail and says nothing adverse about the agency; it means the review has not reached a supported verdict.
A fail requires evidence of a defect, while a pass requires evidence that the relevant gate has been cleared. Do not infer either outcome from a missing record. That distinction lets a reviewer request evidence without converting silence into a negative finding or an unsupported endorsement.
For privacy, assess purposes, controller and processor roles, outreach, retention, rights and deletion using the data protection guide. For advertising, check objective claims, commercial intent, approvals, disclosures, live checks and correction against the advertising rules and CMA creator guidance. These are separate gate questions, not substitutes for one another.
Follow control from delivery into exit
Rights evidence should name the creator work and intended music, territory, duration, platform and archive use. Payment alone does not settle reuse. Put the terms into the commercial contract schedules, then check that the wording relates to the same work and service defined in scope.
Security evidence should show buyer ownership of social media accounts, two-step verification, access logging and account revocation when a person leaves or changes role. These checks concern the accounts and access arrangements used for the service, not a general assurance about the supplier. Keep each record tied to the defined assignment.
Commercial evidence separates agency fees, creator cash, gifts or services, commission, paid media, production, expenses, VAT and internal labour. Compare written quotes on one brief rather than relying on an unitemised total. The campaign budget template provides a way to keep these amounts distinct.
Exit evidence covers data and asset export, deletion, rights, payments, account revocation and correction. These matters belong in contract terms as well as the operational handover. A proposal that promises a workable exit is not proof that the agreed process has been tested or can be completed.
Release only a bounded verdict
No gate can repair a gap at another gate. A clean company filing cannot substitute for a recovery test, and a polished case study cannot establish creator authority. Apply the same evidence request to an in-house option; it receives no assumed pass simply because it is not an external agency.
Move beyond hold only when a named reviewer verifies one exact candidate and service, specialists clear each gate, and a permissioned test produces recorded results. Any pass applies only to that scope and date. The selection checklist can record the decision, while the quality checklist offers a separate reference for campaign delivery.
- Name the reviewer and define the candidate, service and date.
- Obtain the registered name, company number and signatory authority.
- Confirm permissioned client references with comparable scope.
- Link objective claims to evidence and show approval and correction.
- Map privacy purposes, roles, retention, rights and deletion before outreach.
- Obtain a signed rights grant naming work, music, territory, term and media.
- Confirm the buyer owns the accounts and that revocation works.
- Compare itemised written quotes on one brief.
- Record the exit terms and the result of the recovery test.



