UH’s Office of General Counsel (OGC) strongly recommends that UH departments and colleges avoid running giveaways, raffles, sweepstakes or similar prize-based promotions on social media. Even promotions that seem simple can trigger multiple overlapping legal and compliance requirements and may create risk for the University and, in some cases, for individual employees involved in approving or administering the promotion.

Even if a promotion is labeled as a “giveaway,” “raffle,” “contest” or “sweepstakes,” the potential legal risk depends on how it is conducted — not what it’s called.

If you think a giveaway is essential

Because OGC has advised against this type of promotion, any exception should be treated as rare and should not be assumed to be approvable.

If you believe a prize-based promotion is necessary for a specific initiative, do not launch or announce it until you have:

1. Written documentation of the proposed promotion mechanics, including:
   • Eligibility requirements
   • How to enter
   • How winners are selected
   • Prize details and value
   • Timing and geographic restrictions
2. Reviewed the concept with your division leadership and received their approval
3. Requested guidance through appropriate internal channels, which may include OGC