On the heels of reports that the U.S. Federal Trade Commission (FTC) is set to regulate companies and the bloggers they reach out to comes a series of reports about Betty Crocker’s campaign to get bloggers talking about its new line of gluten-free food products.

What struck me was this excerpt from Tiffany Janes’ report in Examiner.com (the website of the San Francisco Examiner):

When blog posts began appearing about the new Betty Crocker gluten-free products, it was apparent that the company was sending out samples to people to test taste and review gluten-free products before they were introduced to the public. There were too many such posts for this to be just ‘friends of friends’ who worked for the company getting in on the action.

In other words, the volume of posts raised eyebrows and suspicions. Janes goes on to explain that “the mystery…is solved” by pointing to a website from General Mills designed to enlist bloggers to write about its products—including the Betty Crocker line—that involves the company sending free product to bloggers who sign up so they can try the foods and then write about them.

Clearly, General Mills wasn’t trying to keep its blogger outreach effort a secret, not with its My Blog Spark website right out there in the open. But until it was “found,” it was only natural for those struck by the sudden blogger interest in Betty Crocker products to wonder if something not quite on the up-and-up was going on.

There is, as this situation suggests, a difference between disclosure and transparency.

They’re related, to be sure, but tactically speaking, they serve different functions. The discoverability of My Blog Spark made the effort transparent. But in this case, transparency is passive. Disclosure could have been a very active process of letting everyone know what you’re doing.

One of the goals of a transparency effort is to preclude any hint of trying to hide your behavior. But it only works if those inclined to point an accusatory finger know that you have, in fact, behaved transparently. In this case, pushing disclosure solves the problem.

Most disclosure isn’t pushed. It’s a statement (such as my disclosure, right here, that General Mills was once a client of mine, several years ago) that is published somewhere. When an executive includes a box on his blog that his posts are edited by his communications staff, that’s typical passive disclosure.

But blogger outreach screams for active disclosure.

A search of press releases on the General Mills Media Center turns up no releases at all announcing the My Blog Spark initiative. By not issuing a press release or making some other kind of disclosure, General Mills didn’t violate any code of ethics or fail to behave transparently. But the fact that bloggers taking General Mills up on its offer led some to ask the ethics question leads me to think that any blogger outreach these days needs to be accompanied by proactive disclosure via press release, RSS feed, tweet or whatever other push channels will get the word out.

I can even see a company that does a lot of blogger outreach—or even PR agencies handling the effort on behalf of their clients—posting regular updates to a blog (with its RSS feed) focused on the company’s outreach programs.

Of course, even pushing disclosure doesn’t not guarantee that people like Tiffany Janes will be aware of it, but when questions arise and people begin digging, the company’s completely open explanation of its outreach program will be right there for everyone to see. As a result, there’s no chance that anyone can construe the company’s campaign as devious or covert.

All of which could go a long way toward keeping the FTC off their backs once those regulations go into effect.