Ad:Check - Advertising Standards Authority

Ad:Check
Understanding advertising regulation
Legal, decent, honest and truthful
Contents
Foreword
Foreword
1
Introduction
2
The Advertising Standards Authority
2
Curriculum context
4
Big question one: Why does advertising
need to be regulated?
8
BQ1 Lesson one: What is the point of advertising?
8
BQ1 Lesson two: The ASA's remit
11
Resources
14
Big question two: How much do ads
influence children and young people?
20
BQ2 Lesson one: Young people as consumers
21
BQ2 Lesson two: Marketplace – Is it OK?
23
Resources
24
Big question three: Should advertisers
have the freedom to say whatever
they want?
30
BQ3 Lesson one: What are the limits?
31
BQ3 Lesson two: Developing an ad campaign
32
Resources
33
Advertising is an essential part of modern life and a modern
economy – informing consumers about the things available
to them, giving them vital information, and persuading them
in a lively way about the merits of particular products and
services. But it’s very important that this information is
accurate, and doesn’t mislead, and can be trusted by the
consumers who see or hear it.
Ensuring that advertising can be trusted is where the
Advertising Standards Authority comes in. The ASA
started 50 years ago, and our job is very simple: to ensure
that advertising in all forms of media – from newspapers,
magazines and billboards through to television, radio and
the internet – is legal, decent, honest and truthful. And if
it fails those tests, then the advertising is either amended
or withdrawn.
In addition we hope Ad:Check will help children and young
people to develop the emotional and critical ability they
might need in order to understand advertising, as well as
encourage them to raise any concerns they may have as
responsible citizens about the ads they see and hear.
Overwhelmingly, advertising here in Britain is both
wonderfully creative and entirely legitimate. Our continuing
work at the ASA does, I hope, help to keep it that way.
Rt Hon Lord Smith of Finsbury,
ASA Chairman
The Advertising Codes we apply to ads concentrate
particularly on two things. First, is the ad inaccurate or
misleading? And second, might it cause offence to people
seeing it, or could it cause harm to anyone, especially
to children?
The protection of children from misleading or inappropriate
advertising has always been at the heart of our work.
And in producing Ad:Check we hope to enable students
to gain a broad understanding of the way advertisements
are regulated in the UK, so that they will gain knowledge
about the high standards which all advertisers are called
upon to uphold.
1
Introduction
Ad:Check provides teachers with a creative and
educationally robust set of resources for use in the
classroom, supplying them with the tools they need
to raise awareness of how advertising is regulated
in the UK and why it should be regulated. Along the
way we hope to promote a broad understanding of
the advertising standards used and applied in the UK.
This will enable students to feel equipped with the
knowledge and understanding they need to be able
to make critical assessments of the ads they see
around them, and, if they feel the need, raise their
concerns about the ads they see and hear with the
Advertising Standards Authority (ASA).
The resource takes a “Big Question” approach
to investigate the role of the ASA in advertising
regulation, by providing lesson plans linked to real-life
ASA case studies to explore why we need advertising,
the remit of the ASA, and the Advertising Codes that
govern what we see and hear. The resource also
contains banks of additional ads with commentaries
explaining the issues they raise. These Ad banks
have been collated to illustrate three key areas of
the ASA’s work in ensuring that advertising does not
mislead, harm or offend, and teachers can draw
on any of these examples to customise and develop
the lessons in the resource if they wish.
The Advertising Standards Authority
The Advertising Standards Authority (ASA) works to make
sure that all UK advertising is legal, decent, honest and
truthful. It is funded by a levy on advertising space, but
operates independently from advertisers and the government.
As well as proactively checking ads from the many millions
that appear every year in the UK, the ASA acts on complaints
to make sure that consumers are protected from misleading,
harmful or offensive ads. Even a single complaint can lead
to a formal investigation and an ad being withdrawn.
alcoholic drinks, health and beauty claims, marketing to
children, medicines, financial products, environmental
claims, gambling, direct marketing and prize promotions.
The ASA works on the principle that advertisers must
adhere to the spirit as well as the letter of the rules, making
it almost impossible for advertisers to find loopholes.
Who judges the ads?
You can complain to the ASA if you:
• think there is something wrong with an advertisement
you have seen or heard
• have difficulty getting goods or a refund for items bought
by mail order or through television shopping channels
• think a special offer or prize promotion has been
unfairly run
• want to stop direct mail from companies sent by post,
fax, text message or email
• think there is something wrong with the marketing on
a company’s website or their social network site.
The ASA Council is the jury responsible for deciding
whether ads have breached the Advertising Codes.
Two-thirds of the Council members are independent
of the advertising industry and the remaining members
have a professional background in the advertising or
media sectors. Collectively they offer a wide range of
skills and experiences, representing perspectives across
society, including young people, families, charities and
consumer groups.
Two bodies with a shared goal to keep
advertising legal, decent, honest and truthful.
Who writes the rules?
The ASA judges ads against the UK Advertising Codes.*
The Advertising Codes are written by the advertising
industry through the Committee of Advertising Practice
(CAP) and the Broadcast Committee of Advertising
Practice (BCAP). The members of these committees
are drawn from the main industry bodies representing
advertisers, agencies and media owners. The Advertising
Codes contain wide-ranging rules designed to ensure
that advertising does not mislead, harm or offend and
is socially responsible, whatever the product being
advertised. The Codes reflect the law and in places go
well beyond it. The Codes also contain specific rules
for certain products and marketing techniques to cover
writes the
Advertising Codes
assesses if ads breach
the Advertising Codes
Visit the ASA website for detailed information on
the role of the ASA
The Advertising Codes are available on the CAP website
How to make a complaint
ASA rulings on the complaints they have received
*The UK Code of Non-broadcast Advertising, Sales Promotion and Direct Marketing.
The UK Code of Broadcast Advertising.
2
The Advertising Standards Authority
Summary of the
Advertising Codes
The Advertising Codes contain hundreds of rules on
many different topics. Below we have summarised some
of the key rules that will help while teaching this resource.
The full Codes can be found here.
General
• Ads must be obviously identifiable as such.
• Marketing communications must be prepared with a
sense of responsibility to consumers and to society.
Misleading
• No ad should mislead, or be likely to mislead, by
inaccuracy, ambiguity, exaggeration, omission
or otherwise.
• Marketers must hold documentary evidence to prove
all claims that are capable of objective substantiation.
Harm and offence
• Ads must not contain anything that is likely to cause
serious or widespread offence. Particular care must be
taken to avoid causing offence on the grounds of race,
religion, gender, sexual orientation, disability or age.
• The fact that a product is offensive to some people
is not grounds for finding an ad for that product in
breach of the Code.
• Ads must not cause fear or distress without justifiable
reason e.g. charity or public sector ads; if it can be
justified, the fear or distress should not be excessive.
Advertisers must not use a shocking claim or image
merely to attract attention.
• Ads must not contain anything that is likely to condone
or encourage violence or anti-social behaviour.
Children
• Ads must not condone or encourage poor nutritional
habits or an unhealthy lifestyle in children.
• Children must not be shown in hazardous situations
or behaving dangerously, except to promote safety.
Children must not be shown unattended in street scenes
unless they are old enough to take responsibility for
their own safety. Pedestrians and cyclists must be seen
to observe the Highway Code.
• Food or drink products that are high in fat, salt or sugar
(HFSS) may not be advertised in or adjacent to TV
programmes commissioned for, or likely to appeal to,
audiences under the age of 16.
Tobacco
• Ads, especially those addressed to or depicting a child,
must not condone or encourage an unsafe practice.
• Tobacco products may not be advertised to the public.
• Ads that are suitable for older children but could distress
younger children must be sensitively scheduled.
Alcohol
• Ads must not condone or encourage practices that are
detrimental to children’s health.
• Ads must not condone or encourage bullying.
• Ads must not portray or represent children in a
sexual way.
• Ads must not imply that children are likely to be ridiculed,
inferior to others, less popular, disloyal or have let
someone down if they or their family do not use a
product or service.
• Ads must not collect personal information from children
under 12 for marketing purposes without the consent
of the child’s parent or guardian.
• Marketing communications for alcoholic drinks should
not be targeted at people under 18 and should not
imply, condone or encourage immoderate, irresponsible
or anti-social drinking.
Gambling
• Marketing communications for gambling must be socially
responsible, with particular regard to the need to protect
children, young persons and other vulnerable persons
from being harmed or exploited.
• Trailers for films or video-games carrying an 18-certificate
or 15-certificate may not be advertised around
programmes made for, directed at, or likely to appeal
to audiences below the age of 16.
• Ads for age-restricted products like alcohol and gambling
must not be targeted at or likely to appeal to under 18s.
• Ads featuring sexual imagery, particularly posters that
children are more likely to see, must be carefully targeted
and avoid causing harm or offence.
• Depictions of violence that may cause distress or
encourage copycat behaviour should be shown only
at appropriate times and in places where children are
less likely to see them.
3
Curriculum context
A study of advertising, why it exists, how it works and
how it is regulated, can offer rich learning opportunities
in Citizenship, and also PSHEE and English.
Ad:Check offers teachers a range of learning opportunities
that will enable students to explore key aspects of
Citizenship. They will engage with examples of real ads
and explore some topical and controversial issues within
the context of their rights, responsibilities, duties and
freedoms as citizens of a diverse and democratic society.
The materials and activities have been developed to allow
teachers flexibility in their approach, and provide them
with resources that:
• encourage active learning, rich in student talk,
discussion and questioning
• prompt students to develop skills of visual literacy,
thinking critically, constructively and creatively in
analysing and evaluating evidence, presenting ideas
in a variety of forms and justifying conclusions
• provide decision-making exercises through which
students will solve problems and develop their analytical
skills while being encouraged to think creatively about
topical issues.
Links to learning – Citizenship
BQ1
Key concepts
BQ2
Lesson one
What is the point
of advertising?
Lesson two
The ASA’s
remit
BQ3
Lesson one
Young people
as consumers
Lesson two
Marketplace –
Is it OK?
Lesson one
What are
the limits?
Rights and responsibilities
Lesson two
Developing an
ad campaign
✓
Exploring different kinds of rights and obligations and how
these affect both individuals and communities.
Understanding that individuals, organisations and
governments have responsibilities to ensure that rights
are balanced, supported and protected.
✓
✓
✓
Investigating ways in which rights can compete and conflict,
and understanding that hard decisions have to be made to
try to balance these.
✓
✓
✓
✓
✓
Key processes
Critical thinking and enquiry
Question and reflect on different ideas, opinions,
assumptions, beliefs and values when exploring topical
and controversial issues and problems.
Research, plan and undertake enquiries into issues and
problems, using a range of information, sources and methods.
✓
✓
✓
✓
Continued...
4
Curriculum context
Links to learning – Citizenship continued
BQ1
Key processes continued
Lesson one
What is the point
of advertising?
Critical thinking and enquiry continued
BQ2
Lesson two
The ASA’s
remit
Evaluate different viewpoints, exploring connections and
relationships between viewpoints and actions in different
contexts (from local to global).
✓
Advocacy and representation
Evaluate critically different ideas and viewpoints including
those with which they do not necessarily agree.
✓
Explain their viewpoint, drawing conclusions from what
they have learnt through research, discussion and actions,
including formal debates and votes.
✓
✓
Present a convincing argument that takes account of, and
represents, different viewpoints, to try to persuade others
to think again, change or support them.
✓
✓
Debate, in groups and whole-class discussions, topical and
controversial issues, including those of concern to young
people and their communities.
Use and interpret different media and ICT both as sources
of information and as a means of communicating ideas.
Lesson one
Young people
as consumers
✓
Interpret and analyse critically sources used, identifying
different values, ideas and viewpoints and recognising bias.
Curriculum opportunities
BQ3
✓
Lesson two
Marketplace –
Is it OK?
✓
✓
✓
✓
✓
✓
Lesson one
What are
the limits?
Lesson two
Developing an
ad campaign
✓
✓
✓
✓
✓
✓
✓
✓
✓
Continued...
5
Curriculum context
Links to learning – Personal, Social, Health and Economic Education (PSHEE)
BQ1
Key concepts
BQ2
Lesson one
What is the point
of advertising?
Diversity
Lesson two
The ASA’s
remit
BQ3
Lesson one
Young people
as consumers
✓
Understand that all forms of prejudice and discrimination
must be challenged at every level in our lives.
Lesson two
Marketplace –
Is it OK?
Lesson one
What are
the limits?
✓
✓
✓
✓
✓
✓
✓
✓
✓
✓
✓
Lesson two
Developing an
ad campaign
Key processes
✓
Critical reflection
Reflect critically on their own and others’ values.
✓
Curriculum opportunities
Use case studies, simulations and scenarios to explore
personal and social issues and reflect on them in relation
to their own lives.
Take part in individual and group discussion to consider
personal, social and moral dilemmas and the choices and
decisions relating to them.
✓
✓
Links to learning – English
Key concepts
Competence
Being clear, coherent and accurate in spoken and
written communication.
Being adaptable in a widening range of familiar and
unfamiliar contexts within the classroom and beyond.
✓
✓
Continued...
6
Curriculum context
Links to learning – English continued
BQ1
Key concepts continued
BQ2
Lesson one
What is the point
of advertising?
Lesson two
The ASA’s
remit
BQ3
Lesson one
Young people
as consumers
Lesson two
Marketplace –
Is it OK?
Lesson one
What are
the limits?
Competence continued
Lesson two
Developing an
ad campaign
✓
Making informed choices about effective ways to
communicate formally and informally.
Key processes
Speaking and listening
Engage an audience, using a range of techniques to
explore, enrich and explain their ideas.
✓
Listen and respond constructively to others, taking
different views into account and modifying their own views
in the light of what others say.
✓
Understand explicit and implicit meanings.
Reading for meaning
Assess the usefulness of texts, sift the relevant from the
irrelevant and distinguish between fact and opinion.
✓
✓
✓
✓
✓
✓
✓
✓
✓
✓
✓
✓
✓
Understand how audiences and readers choose and
respond to texts.
Understand how the nature and purpose of texts influences
the selection of content and its meanings.
✓
✓
✓
Writing
Use persuasive techniques and rhetorical devices.
✓
✓
✓
✓
Curriculum opportunities
Write for contexts and purposes beyond the classroom.
✓
✓
7
Big question one: Why does advertising need to be regulated?
Teacher context
Advertising calls the public’s attention to a product,
service or need. Companies spend large amounts of
money (nearly £16 bn in 2011) on advertising
each year in the UK. (Source: Advertising Association
Advertising Statistics, and Institute of Practitioners in
Advertising, IPA.) But what does advertising do for us?
Do we need it? What purpose does it serve?
Lesson one: What is the point of advertising?
Pre-lesson task 5 mins
To share findings at start of lesson
The lessons in this section will give students
opportunities to argue and decide the balance of
responsibilities – how far advertising informs and
entertains and is important for economic growth, but
also what consideration needs to be given to the rights
of citizens not to be misled, harmed or offended.
Ask students to bring with them an example of a piece
of advertising: perhaps an ad for a favourite item,
something from a magazine or newspaper, something
spotted as a pop-up on the web or something that
strikes them as a particularly good or bad piece of
advertising. As the topic progresses, these can form
part of a developing display of materials that students
can discuss, annotate or deconstruct.
Students will have opportunities to:
Objectives
• explore the nature and purpose of advertising and
why it needs to be regulated
• become familiar with the ASA’s remit and their powers
• become familiar with where the Codes governing
advertising come from
• write and speak to argue and persuade
• distinguish between fact and opinion
• develop a critical understanding of some of the
verbal and visual language of advertising
• write in support of, or opposition to, a real-life ASA
case study
• draft an ad for the ASA.
• To know that advertising appears in many different
forms and contexts.
They will explore:
Companies, charities and the government spent
nearly £16 bn on advertising their products and
services in the UK in 2011.
• why we need advertising controls and what they
should be
• what the controls are on the ads we can see
and hear
• whether we all need to be protected, or only some
of us
• whether advertising is a big influence on us anyway.
• To explore the nature and purpose of advertising.
• To consider why advertising needs to be regulated.
1 hour
Issue the statements on the cards on BQ1 / Resource
sheet 1 to pairs of students. Ask them to read through
all of the points on the cards carefully before creating a
‘Diamond 9’ of the points that they think best explain
the purpose of advertising.
Why Diamond 9?
The aim is to promote lots of discussion in a relatively
short space of time. It is an effective way of getting
everyone to agree a short list of priorities.
Students are given a list of issues or questions on
separate cards so they can be moved around easily.
They are asked to select nine of the most important
items and arrange them on a diamond-shaped grid.
The most important item is placed at the top of the
diamond. The least important is placed at the bottom of
the diamond. Items in each row are of equal importance.
Activity one: What is the point
of advertising?
Step one 10 mins
But what does advertising do?
Why do advertisers think it is worth spending so
much money on it?
Continued...
8
Big question one: Why does advertising need to be regulated?
Advertising helps promote and
stimulate competition.
Advertising draws attention to a product or service.
Advertising tells consumers how much things cost.
Advertising keeps consumers up to date
with new developments.
Advertising makes us aware of different brands.
Advertising helps fund media.
There are 20,000 jobs in the advertising industry.
Completing a Diamond 9
• Students read the list of items and think about their
importance.
Q/A
• In the group they discuss their ideas and select the
nine statements they believe to be the most important.
• Do students think that advertising is necessary?
• Students then sort the chosen nine items into the
diamond pattern according to order of importance.
• What benefits does advertising bring us?
• The group should all agree the order of importance
and be able to justify their choices.
• What are they?
Variation Try introducing
two blank wild cards where
students can write their own
ideas if they wish.
Advertising helps fund culture and sport.
• Are there any negatives attached to advertising?
At this point take a show of hands to indicate whether
on balance they think advertising brings more positives
than negatives.
Ask students to list the types of advertising they
encounter and the contexts in which they see or
hear it.
Given that advertising is a feature in all of our lives, ask:
Advertising helps businesses make a profit.
Advertising tells consumers what things
they must have.
Step three 5 mins
Link to Activity 2
Step two 10 mins
Debrief
Can advertisers say whatever they want?
Q/A
Advertising helps change society’s behaviour.
Advertising makes us loyal to certain brands.
Advertising tells us where to access
products and services.
Advertising warns people about
dangerous activities.
Ask students to feed back on the points that they
feel give the clearest explanation of the purpose of
advertising. Pairs of students should present their
selection to the rest of the class and explain briefly
how they arrived at this selection. They should be
prepared to justify their decision-making and explain
why they prioritised one item over another. The whole
class can now attempt to identify any common
choices or any agreement on the statements that
best explain the purpose of advertising.
Advertising can be funny and entertaining.
9
Big question one: Why does advertising need to be regulated?
Activity two: Can advertisers
say whatever they want?
Teacher context
Using two ads from a historical context – a time before
the ASA was established – students will discover how
advertisers could at one time easily make misleading /
harmful claims.
The ad for Maltesers, with its claim that
“It’s the chocolate that can help you stay
slim”, would also now fall foul of Advertising
Codes, and in fact, in October 2008 the ASA
upheld complaints about a TV advertisement
for Maltesers on the grounds that saying
the chocolates were “less than 11 calories
each” gave the misleading impression that
Maltesers were a low-energy food.
See ruling on this case
See the ASA site for a brief history of ad regulation.
Find out more about Code rules:
The ad for Craven ‘A’ cigarettes would
no longer be allowed – regulations
around advertising tobacco products
have tightened over time.
Misleading advertising
Rules on health or nutrition claims (non-broadcast)
Rules on health or nutrition claims (broadcast)
• 1965 – Cigarette advertising is
banned on television (cigars and
loose tobacco can continue to be
advertised until the early 1990s).
• 1975 – New rules for other types of
cigarette advertising introduced, along with pre-vetting.
• 2003 – The Tobacco Advertising and Promotion
Act 2002 came into force, prohibiting the advertising
and promotion of tobacco products. It does not,
however, cover ads for rolling papers or filters.
Find out more about the Code rules:
Tobacco products
Rolling papers and filters
Step one 15 mins
Think, Pair, Share – a three-stage cooperative learning
activity where:
• individuals think silently about the questions posed
• individuals pair up to exchange thoughts
• the pairs share their responses with other pairs,
other teams, or the entire group.
Ask students to look at the ads shown in BQ1 / Resource
sheet 2 (or PowerPoint presentation BQ1 Activity 2).
Allow individual thinking time so each student can
consider the ads without the accompanying questions.
Bring students into pairs and ask them to share their
thoughts to answer the questions for each ad.
Step two 10 mins
Debrief
Once they have worked through these questions in
pairs, take responses from the whole group on each ad
in turn.
Responses from the whole group should identify the
fact that these ads – and the claims that they contain –
would not be seen today.
Advertising tobacco products is prohibited. Advertisers
cannot make misleading claims such as smoking can be
good for your throat or chocolate can help keep you slim.
The ads we see today are controlled or regulated.
• But who is responsible for regulating the claims that
can be made by advertisers?
• What are the rules about what can be shown, or the
claims that can be made?
Step three 5 mins
Homework / Research assignment
Task students with identifying the organisation
responsible for checking that consumers are protected
from ads making misleading claims, or likely to cause
us harm or offence. Find out what its role is. Identify
three products (other than cigarettes and chocolate)
where there are rules about how they can be advertised.
Show the questions. Allow further time for students to
consider their individual responses to the questions.
10
Big question one: Why does advertising need to be regulated?
Lesson two: The ASA’s remit
1 hour
Objectives
Activity two: What makes people
complain about ads?
• To understand the ASA’s remit and its powers.
• To understand areas of advertising governed by the
Advertising Codes.
Teacher context
• To engage with the ethics surrounding advertising.
Many millions of ads appear in the UK. The ASA monitors
ads and acts on complaints from organisations or
individual members of the public.
Reveal actual collated information.
Complaint themes 2009 – 2011
Language
3,579
Depiction of children
• To engage critically with an ASA case and ruling.
4,070
4,813
Depiction of men
Depiction of women
6,217
Violence
311
Homosexuality
285
Animals
Activity one: The ASA’s remit
Starter 10 mins
Explore with students what they found out from
their homework / research task set at the end of the
previous lesson. Use BQ1 / Resource sheet 3
to help summarise / reinforce their findings.
• Highlight the ASA logo and strapline and clarify
that its role is to ensure that the ads we see
and hear:
– are legal, decent, honest and truthful
– do not mislead, harm or offend and are
socially responsible.
• Explore the areas of our lives where we might
encounter ads. (Outlined on BQ1 / Resource Sheet 3.)
• Explore the areas of advertising that fall under the
ASA’s remit. (Outlined on BQ1 / Resource Sheet 3.)
If the ASA judges that an ad has broken the rules it can
insist that it is either changed or withdrawn. There are
detailed Advertising Codes setting out what is and is
not acceptable. A single complaint to the ASA can lead
to an ad being changed or withdrawn.
In 2011:
• the ASA handled 31,458 complaints about 22,397
different ads
• they judged that 4,591 ads had to be either changed
or withdrawn
• nearly 94% of the complaints came from members
of the public.
Step one 10 mins
Q/A
What issues do students think are likely to be the most
complained about? Collect ideas from students and
collate on the whiteboard.
Complaint
themes
2009 – 2011
1,591
Sex
4,079
1,102
Race
Religion
1,666
617
Disability
17,941
Misleading*
0
5,000
10,000
15,000
20,000
*Based on complaints about misleading prices, before/after images,
exaggeration, post-production techniques, sales promotions and small print.
• How do these topics compare with the list compiled
from students’ ideas?
• Does anything surprise them? Does the work of the
ASA sound straightforward?
• How straightforward would it be to handle complaints
about sexism, racism, homosexuality, violence
or religion?
• Does everyone share the same concerns, feelings or
beliefs about these topics?
Will the words legal, decent, honest and truthful mean
the same to everyone? What offends me, might not
offend you. Your idea of what is “decent” might be very
different from mine. Is it always easy to define “honest”?
11
Big question one: Why does advertising need to be regulated?
Activity three: You be the judge
• Do students think these complaints are justified?
• Do students think that the ad is acceptable as it is?
Teacher note
This activity uses a Paddy Power ad that provoked a
lot of complaints to the ASA. See the ad in full here.
A summary of the ASA ruling is provided in BQ1
Resource sheet 4 teacher notes for quick reference.
For a bank of ads to use as alternatives or in addition
to this, see the Ad bank.
Step one 20 mins
Tell students they are about to watch a video that
shows one of the most complained about ads in recent
years. What do they see in the ad that may have
provoked complaints?
Working in groups of three or four, students should
watch BQ1 / Video resource 1. (Available in summary
as BQ1 / Resource sheet 4 student summary.)
Q/A
Working in their groups, students should draft out the
main points of argument on both sides that the ASA
would have to consider before coming to a conclusion.
Q/A
If they were a member of the ASA Council, how would
they respond to these complaints? Giving their reasons
for their decision, would they:
no breach of rules regarding likelihood of causing harm
or offence, did not encourage or condone violence or
cruelty, would not cause serious distress, didn’t show
harmful or negative stereotypes.
Full ruling details are available here.
• How many students agree with the ASA decision?
Step three 5 mins
Homework activity
EITHER
• insist on changes e.g. changes to the content of the
ad or time it could be shown
Write a formal letter to the ASA supporting the complaints
about the ad and try to persuade the ASA to withdraw it.
• ban this ad
• let the ad go ahead as it stands?
Step two 15 mins
Plenary
Ask groups to vote on whether the ad should be
accepted as it is or whether it should be withdrawn.
Complete a tally on the board.
Reveal that 1,089 viewers objected to this ad.
OR
Write in support of the ad, arguing that it is amusing
and effective.
You should mention in your letter the UK Code of
Broadcast Advertising rules governing:
• causing harm or offence
• encouraging or condoning violence or cruelty
Can students suggest what might have provoked
the complaints?
Ask students to justify their decisions in one or two
words only – e.g. amusing, cruel to animals, insulting
to blind people, offensive.
220 viewers objected that the ad was offensive to
blind people.
Record these thoughts on the board.
OR
Ask students to look at their list. Which do they think
would be the deciding factors influencing the decision
of the ASA?
Write to the ASA commending an ad that you have
recently seen. Explain why you think it is effective.
1,070 viewers objected that the ad was offensive
and harmful, because it might encourage or condone
cruelty to animals.
Reveal the decision of the ASA – that the complaints
were not upheld – and share the reasons for the decision:
• causing serious distress
• showing harmful or negative stereotypes.
N.B. This is a class activity. If you choose to actually
send the letters to the ASA, you will not receive a
personalised response.
12
Big question one: Why does advertising need to be regulated?
Extension activity
Advertise the ASA
See BQ1 / Resource Sheet 5.
Students should look at the examples of ads on
the worksheet, widely used by the ASA in the
press. Their task is to design an alternative ad
to explain and promote the work of the ASA to
young people.
They should draw on the work they
have covered so far as well as
carrying out additional research
by visiting the ASA website.
13
BQ1 / Resource sheet 1 student sheet
Lesson one
Activity one: What is the point of advertising?
Advertising helps promote and
stimulate competition.
Advertising keeps
consumers up to date
with new developments.
Advertising draws attention
to a product or service.
Advertising helps fund culture
and sport.
Advertising helps change
society’s behaviour.
There are 20,000 jobs in
the advertising industry.
Advertising helps businesses
make a profit.
Advertising makes us aware
of different brands.
Advertising can be funny
and entertaining.
Advertising tells consumers
how much things cost.
Advertising makes us loyal
to certain brands.
Advertising tells us where to
access products and services.
Advertising tells consumers
what things they must have.
Advertising helps fund media.
Advertising warns people about
dangerous activities.
✃
14
Lesson one
BQ1 / Resource sheet 2 student sheet
Activity two: Can advertisers say whatever they want?
Craven ‘A’, 1930s
Maltesers, 1950s
What is this advertising?
“Choose the chocolates that
can help you keep slim...”
What claims are being made for the product?
What image is it portraying?
Could a company make the same claims
for this product today? Why? Why not?
What is this advertising?
What claims are being made
for the product?
What image is it portraying?
Could a company make
the same claims for this
product today?
Why? Why not?
15
BQ1 / Resource sheet 3 student summary
Lesson two
Activity one: The ASA’s remit
ASA – Legal, decent, honest and truthful
The ASA is independent but works closely with the advertising industry. The decisions
it makes are based on the UK Advertising Codes, which are written by the Committee of
Advertising Practice (CAP).
writes the
Advertising Codes
assesses if ads breach
the Advertising Codes
The work of the Advertising Standards
Authority (ASA) covers advertisements in:
The work of the Advertising Standards
Authority (ASA) does not cover:
• Magazines and newspapers
• Sponsorship e.g. of events or TV programmes
• Radio and TV
• Packaging
• Television shopping channels
• Shop windows
• Posters
• Telephone calls
• Cinema
• Fly-posting
• Direct mail (advertising sent through the
post and addressed to you personally)
• Private classified ads
• Internet, including a company’s own
marketing on its own website or social
networking page, as well as in paid-for space
• Press releases
• Leaflets and brochures
• Online editorial
• Commercial email and mobile messages
• Statutory / public notices
• Political ads
Many millions of ads appear in the UK each year.
The ASA monitors the media to make sure ads
don't break the rules and acts on complaints from
organisations or individual members of the public.
If it judges that an ad has broken the rules, it
can insist that it is either amended or withdrawn.
The ASA can act on a single complaint.
The following products have specific rules
under the Advertising Codes, as to how
they can be advertised to consumers.
Alcohol
Gambling
Food and soft drinks
Health and beauty products
Tobacco
There are also Code rules that relate to:
Harm and offence
Environmental claims
Racism
Children and advertising
Scheduling ads at appropriate times
Displaying ads in appropriate places
Misleading claims
• CD ROMs, DVDs, videos and faxes
• Sales promotions (special offers, prize draws
and competitions)
16
BQ1 / Resource sheet 4 student summary
Lesson two
Activity three: You be the judge
Paddy Power plc – July 2010
A TV ad for a bookmaker showed a game of
football being played by two teams of blindfolded
men, using a ball with a bell inside it. The ad
opened with a shot of a kitbag marked “Blind
Wanderers FC”, then showed the players
mid-game. One player kicked the ball off the
pitch but then a cat, wearing a bell on its collar,
ran onto the pitch, with its bell ringing. The
referee was about to blow his whistle, when
one of the men was shown taking a kick.
There was a thud and loud meow, although no
contact between the player and the cat was
shown on screen. A man in a suit appeared
on the pitch, patted the shoulder of the player
who had taken the kick and said: “Paddy
Power can’t get Tiddles back, there’s nothing
we can do about that, but we can get you your
money back with our money-back specials”
and handed the player some bank notes.
Issue
1,089 viewers objected to this ad.
220 viewers objected that the ad was
offensive to blind people; and
1,070 viewers objected that the
ad was offensive and harmful,
because it might encourage
or condone cruelty to animals.
There was a shot of the cat walking along the
branch of a tree, meowing. The final voice-over
said: “Check ’em out before you bet at Paddy
Power ...” and the player taking the kick was
shown again, in slow motion, and a faint meow
was again heard in the background.
17
BQ1 / Resource sheet 4 teacher notes
Lesson two
Activity three: You be the judge
Teacher notes
Paddy Power plc – July 2010
The ASA’s final decision was:
Not upheld
1. The action in the ad would be interpreted by most
viewers as a humorous depiction of a fictional situation,
with the humour derived from surreal and improbable
circumstances, when an unforeseeable and accidental
action occurred.
The ASA said it was not offensive in itself to create an
advert referring to people with a disability.
Paddy Power said it featured an action “so unlikely that
it was absurd”.
Paddy Power said the advert did not show the cat being
kicked or suffering any violence or cruelty. It was clearly
and deliberately shown to be unharmed at the end of
the item.
2. It was unlikely to be seen by most viewers as malicious
or implying that blind people were likely to cause harm
to animals whilst playing football.
3. The ad was unlikely to be seen as humiliating,
stigmatising or undermining to blind people and was
unlikely to cause serious or widespread offence.
Paddy Power had chosen a blind football match to
promote a lesser-known sport – the World Blind Football
Championships were going to take place in 2010.
Paddy Power produced a letter of support from the
manager of the England Blind Football Team.
All the players in the ad were actual blind football players,
many of whom had represented the national side.
18
Lesson two
BQ1 / Resource sheet 5 student sheet
Extension activity
Advertise the ASA
Look at these ASA ads, widely used in the press.
Their purpose is to inform us about the role of the ASA.
The audience is the general public and the language and
style are simple, clear and direct.
What do they tell us about the work of the ASA?
How effective are they?
Could they be more effective in reaching young people?
Your task is to draft an alternative ad for the ASA. The
purpose must remain to inform about the role of the
ASA, but the intended audience must be young people.
Develop your ad with this in mind, changing the language
and style to fit the new audience.
Think carefully about where this ad would be best placed
to reach its new audience.
FIND OUT MORE about the work of the ASA
by visiting their website.
www.asa.org.uk
19
Big question two:
How much do ads influence children and young people?
Using industry and ASA information, students will have
opportunities to:
• evaluate information and make informed judgements
• argue a case on behalf of others as well as themselves
• clarify their own values and attitudes
Teacher context
The size of the UK market for products aimed at children
and young people is large and growing. Children and
young people often have an influence on family spending,
including over what goods are bought for the home
as well as products they want to own for themselves.
• examine some of their own spending habits
• discuss ASA rulings relating to children and advertising.
They will explore:
• how the Advertising Codes define a “child”
• what the limits are on what children and young people
can see
• whether young consumers need protection and what
the dangers are
• whether we are obsessed with consumerism.
There are strict rules on how goods and services are
marketed to children and young people so that they
are protected from unfair pressure to buy products and
aren’t encouraged to engage in dangerous behaviour.
Ads must not undermine parental authority, although
a recent report, commissioned by the Government,
“The Bailey Review”, found that some parents in the UK
are concerned by the increasing commercialisation of
modern childhood, resulting in children and young people
feeling under pressure to have specific branded clothes
and consumer items in order to “fit in” with their peers.
Teacher note
The Advertising Codes class a
child as someone under the age
of 16 – see the CAP website for
the rules relating to advertising
and children.
Teacher note
At some point teachers may choose to raise
the topic of “Brand bullying” – being bullied
or stigmatised for not having the “right”
labels, clothes, accessories or gadgets.
It is perhaps a topic that will already
have been addressed in previous
work on bullying in general.
20
Big question two: How much do ads influence children and young people?
Lesson one: Young people as consumers
Objectives
• To consider whether young consumers need
specific protection.
• To evaluate advertising rules and make
informed judgements.
• To argue a case on behalf of others as well
as themselves.
Activity one: But everyone’s
got one!
Step one 5 mins
Starter
1. Ask students to think about the things in their
life that they enjoy and that make them happy.
They have 30 seconds to write down a list of all
of these things – it’s a list just for them; they won’t
have to share it if they don’t want to.
2. Ask students to look at their lists – Did anyone
list things in life that are free? (Family, friends,
hobbies, socialising ...)
3. How many of the items on their lists are the sort
of things we could define as consumer goods or
“must-have” items? (Phones, games, clothes ...)
4. How many of the things they have recorded
have a preferred brand? Why do you need a
preferred brand?
1 hour
Step two 10 mins
Debrief
Step three 5 mins
Link
Q/A
There are strict controls on advertising aimed at
children and young people.
Are young people at risk of becoming too concerned
about having the right labels or the right consumer
goods? Some people have argued that we are at risk
of becoming “obsessed” with consumerism.
Looking at the so-called “must-have” items:
• What makes you want these goods? What are the
main influences?
The ASA makes sure that ads targeted at children
don’t contain anything that is inappropriate or harmful
and also ensures that young adults are protected.
The Advertising Codes define a child as someone
under the age of 16, but there are further rules in place,
like timing restrictions, that are designed to protect
younger children.
• What about people who don’t have these items?
What might their reasons be for not buying them?
• Do you think there might be some people who
place consumer goods as being more important
than friends and family? Why might this be?
Is this right?
• Do you think that advertisers need to be made
aware of these issues?
Teacher note
You may want to recap – the ASA’s role is to
regulate ads by applying the Advertising Codes
(see BQ1, Lesson 2, Activity 1 / Resource
sheet 3). The rules are written to ensure
that ads do not mislead, harm
or offend and that they
are socially responsible.
• How aware are students of what these controls mean?
• Do they think any controls are needed at all? Or do
they think there should be more controls?
See the key rules relating to children and advertising here.
21
Big question two: How much do ads influence children and young people?
Activity two: Advertising
controls – Justified?
Step one 10 mins
Statement line-up
Tell students that they will be presented with a range of
descriptions of ads that could be encountered in different
contexts. They will be given a choice of deciding whether
they think the ads in their suggested context present no
problems or whether they think that the ads should be
subject to some control. They should consider whether
the ads raise general issues or issues more specific to
children and young people.
Identify one end of the room as “No problem” and the
other as “Problem”. Using BQ2 / Resource sheet 1,
read out the description of a potential advertising scenario
and then ask students to place themselves somewhere
along the “Problem / No problem” continuum.
Once students have settled themselves somewhere
along the line, they should be prepared to justify their
position and explain the reasoning behind their decision.
• Can they arrive at a consensus?
• A majority decision?
Reveal whether the scenario would actually be permitted
using the information from the Teacher notes on BQ2 /
Resource sheet 1 before moving on to discuss the
next scenario.
Step two 15 mins
Now ask students in pairs to consider some more ads to
identify the issue raising concern and make a judgement
about the level of control needed.
Step four 5 mins
Plenary
From the exercises they have just completed:
• Do students accept the need for advertising controls?
Using BQ2 / Resource sheet 2, students should
consider the ads and the context given on the task
sheet and decide:
• How far do they accept that children and young people
need to be protected by additional controls?
• Is this an issue most likely to affect children, or does
it affect everyone?
Step five
Homework
• Is this an issue needing a lot of control, or none at all?
Once decided, they should plot a point on the chart for
each ad.
Remind students that in this context, “child” is defined
as being under the age of 16.
Step three 10 mins
Debrief
Ask students to visit the Committee of Advertising
Practice (CAP) website www.cap.org.uk and research
the Advertising Codes relating to children – What are
the four main rules governing advertising and children?
Look at the most recent ASA rulings.
Identify one case relevant to children / young people,
or one case about an ad they have seen:
• Did they agree with the complaints?
Take feedback from students. (See teacher background
information on the ads on BQ2 / Resource sheet 3.)
• Did they agree with the ASA’s decision?
• Which ads needed most control?
• Which ads needed little or no control?
• What were the topics / contexts they identified as
being particularly important for children?
Point out that the work of the ASA in implementing
the Advertising Codes involves balancing a range of
possibilities, from no action at one end of the scale, to
changes in content, changes in location and changes
in scheduling all the way to a complete ban at the other
end of the scale.
22
Big question two: How much do ads influence children and young people?
Lesson two: Marketplace – Is it OK?
Objectives
• To explore the advertising rules.
• To make personal judgements on acceptable content.
• To assess the importance of context in acceptability.
Activity one: Is it OK?
Step one 5 mins
Introduction
Explain that this activity gives students the opportunity
to further explore the Advertising Codes. They will look
at both the content of ads and the context in which they
might be encountered. They will be asked to judge how
important context is in deciding on the acceptability
of an ad. See BQ2 / Resource sheets 4 – 5 for teacher
and student resources for this activity, or look at the
Ad banks for other examples you might want to use.
Step two 20 mins
The marketplace
• Divide the class into groups of five or six students.
Give each group a copy of one ad with a note
explaining the context in which it appeared see
BQ2 Images for copies of ads.
• Ask each group to nominate a “recorder” who will stay
with the ad at their table and record the opinions of the
other groups as they visit.
1 hour
• Each group has to discuss the ad on the table and
help the recorder to summarise their discussion –
either using notes or symbols to represent their views.
After summarising with the recorder, the groups move
clockwise to the next table, leaving the recorder in place.
• Recorders stay to receive members of another group.
The visiting group discusses the ad on the table in front
of them, with help from the recorder and with reference
to the notes the recorder has already made. The recorder
adds the group’s comments and opinions to their notes.
• All groups then move on to the next task until they are
back where they started.
• When groups return to their own tables, they help the
recorder compose a summary of all the comments
received on their ad.
Step three 20 mins
Debrief
Ask recorders and other group members:
• Were some ads easier to evaluate than others? Why?
• How important is the context of an ad in determining
its acceptability?
• Which of the ads proved to be a problem?
During the debrief, give students information on the
complaints made to the ASA and the final ASA ruling.
Were there any ads that the students would not allow
in any context?
Step four 15 mins
Plenary
• What did you learn as a result of working with others?
• Was it easy to reach a consensus decision?
Ask each group to explain their findings on specific ads,
making sure all groups comment and all ads are covered.
• How difficult is it to balance opposing views?
• The ASA Council decisions are based on a majority
vote – is this a better method?
Teacher note
This exercise easily allows questions of different
levels of challenge to be allocated to tables /
individuals according to ability. Teachers
can ask for part answers from
numbered heads: “Can anyone
who was number 4 tell me ...”).
• Finally take a class vote on each of the ads. Is it:
Acceptable as it is?
Acceptable with changes?
Not acceptable?
• Over the course of the lesson, students will move
around the room in groups of four or five, discussing
each ad in turn.
23
BQ2 / Resource sheet 1 teacher notes
Lesson one
Activity two: Advertising controls – Justified?
Teacher notes
Statement line-up – Problem or No problem?
These are all issues covered in the Advertising Codes.
Some would not be allowed, some would be allowed
with some modification, while others would pose
no problem.
1. Violence being shown as humorous.
Can be a problem but light-hearted, cartoonish
depictions of violence may be acceptable.
2. Advertising alcohol around children’s
programmes.
Strict guidelines – ads can’t be shown around children’s
programmes or channels likely to have particular appeal
to children.
3. Advertising gambling at tea time.
Could be a problem – gambling ads cannot be seen
to appeal to young people or reflect or be associated
with youth culture. Just because it’s at tea time,
however, doesn’t mean the programme is targeted
at young people.
4. Using a children’s TV celebrity to advertise
fast food.
It is prohibited to use a kids’ TV personality in an ad
broadcast in ad breaks around a programme they’re
appearing in, because it might cause confusion about
the difference between the programme and the ad.
Using a children’s TV celebrity might be a problem if the
fast food is high in fat, salt or sugar – although not all
fast food is.
5. Images of guns being brandished in an
aggressive manner.
Not acceptable – always likely to be problem.
24
BQ2 / Resource sheet 2 student sheet
Lesson one
Activity two: Advertising controls – Justified?
Problem or No problem?
Look at these advertising situations. Do any
of them pose a potential problem? Might there
need to be some regulation of who can see
what, when and where? Are some things
more concerning if young people are exposed
to them? Are some things a concern for
everyone, child and adult alike?
X
Taking each situation in turn, mark on the grid
where you think it lies – for example point X
shows an issue that would mostly concern
young people, but that isn’t a very serious
issue. Point Y shows an issue that concerns
everyone and is a significant problem.
1. Advertising alcohol as something that
can make you attractive.
2. Advertising high-fat, high-sugar
and high-salt food or drinks around
children’s programmes.
3. Advertising slimming products on
daytime TV.
4. Advertising skin cream to permanently
reduce wrinkles.
A concern for young people
5. Advertising skin cream to reduce
wrinkles using a Photoshopped model.
No control
Control
6. Advertising sexy underwear on a
bus stop poster.
7. Advertising sexy underwear on a
bus stop poster outside a school.
8. Advertising a sports drink as healthier
than water.
A concern for everyone
Y
9. Advertising a clothes label
using skinny models.
25
BQ2 / Resource sheet 3 teacher notes
Lesson one
Activity two: Advertising controls – Justified?
Teacher notes
All of the examples would be considered by the ASA.
Some would not be allowed, some would be allowed with
some modification, while others would pose no problem.
They are all issues covered in the Advertising Codes.
1 Advertising alcohol as something that can make you
attractive – strict guidelines – ads can’t link alcohol with
seduction, sex or social success.
2 Advertising high-fat, high-sugar and high-salt food or
drinks – is not allowed around children’s programmes.
3 Advertising slimming products on daytime TV – no
problem in itself, but there are rules on the claims that
can be made for slimming products, no matter where and
when they are advertised. Claims must be truthful and
advertisers must hold evidence to back up their claims.
4 Advertising skin cream to reduce wrinkles permanently –
would be allowed if the advertiser has evidence it works.
It’s not allowed at the moment because no creams are
proven to do that!
6 Advertising sexy underwear on a bus stop poster – may
prompt the ASA to ask for changes if the ad is regarded
as too sexual.
7 Advertising sexy underwear on a bus stop poster outside
a school – may prompt the ASA to ask for changes in
content or a change of location.
8 Advertising a sports drink as healthier than water –
not allowed because it is against good dietary advice.
See recent ASA ruling.
9 Advertising a clothes label using skinny models – can
cause complaints from the public – but complaints are
not always upheld. It depends on whether the model
is just slim or is unhealthily underweight.
See recent ASA rulings:
Hennes and Mauritz
Drop Dead Clothing
5 Advertising skin cream to reduce wrinkles using a
Photoshopped model – not allowed. Even claiming
temporarily to reduce the appearance of wrinkles would
be a problem. See this recent ASA ruling of a L’Oréal
advertisement featuring Julia Roberts.
26
BQ2 / Resource sheet 4 student sheet
Lesson two
Activity one: Is It OK?
Recording sheet
Ad
Context
Questions to consider
What is the content of this ad?
What is the context for the ad?
What advertising guidelines could apply to it?
Is it acceptable?
27
BQ2 / Resource sheet 5 teacher notes
Lesson two
Activity one: Is It OK?
Teacher notes
Ad A – Gambling ad.
Context – YouTube
The complaint – That the ad was
irresponsible, because it was likely
to appeal to children.
Ad B – Ad for ringtones featuring the
Ad C – Ad for children’s clothing where the
American ventriloquist, Jeff Dunham, with
his dummy, “Achmed, the Dead Terrorist”.
The ringtones used some of the phrases
from Mr Dunham’s act, including “Silence!
I kill you”, “Stop touching me” and “Knock,
knock. Who’s there? Me. I kill you”.
child models are shown holding plastic bags
near their faces.
ASA decision – The Advertising Codes require that ads
should not be likely to be of particular appeal to children or
young persons, especially by reflecting or being associated
with youth culture. Even though Spider-Man appeals to
some adults, the ASA Council considered that the depiction
of the popular comic book character was likely to have
particular appeal to children and young people, regardless
of the context in which it appeared. Therefore, we concluded
that the ad breached the Code. The complaint was upheld.
Context – A pop-up ad on a website in paid-for ad space.
Details of full ruling
Details of full ruling
The complaint – A viewer challenged whether the ad was
offensive because he believed it was racist towards Muslims.
ASA decision – The ASA noted that at no time did the ad
make any reference to terrorism or the Islamic faith, and
therefore concluded the ad was unlikely to cause serious
or widespread offence. The complaint was not upheld.
Context – In a children’s clothing catalogue.
The complaint – Complainants objected that
the ad was irresponsible because it could be copied
by children, leading to their physical harm.
ASA decision – Although the catalogue was sent to
parents, the ASA felt there was a risk of it being left where
children could see it and that they could possibly try to
emulate it. The complaints were therefore upheld.
Details of full ruling
28
BQ2 / Resource sheet 5 teacher notes
Lesson two
Activity one: Is It OK?
Teacher notes continued
Ad D – This ad for “Miraculous deals
on Samsung Galaxy AndroidTM
phones” featured a cartoon-like
illustration of Jesus Christ grinning
broadly and winking, pointing a
finger with one hand and displaying a thumbs-up sign with
the other. The Sacred Heart was featured on his chest.
Context – Poster on the side of a bus where anyone could
see it at any time.
The complaint – 98 complainants challenged whether the
ads were offensive, because the depiction of Jesus Christ
and the Sacred Heart, the use of the term “miraculous” in
that context and their publication during the Easter period
were disrespectful to the Christian faith.
ASA decision – The ASA agreed with the complainants
that the ads were disrespectful to the Christian faith and
were likely to cause serious offence, particularly to Christians.
The ads were banned and must not appear again.
Details of full ruling
Ad E – Ad for Beyoncé Heat perfume
showed the singer wearing a revealing red
satin dress and dancing seductively, showing
images of her chest, back and thighs.
Ad F – Condom ad
Context – This poster formed part
of a sponsorship campaign by Durex for
Take That’s concert tour.
Context – On TV at 8 pm.
The complaint – Viewers complained that the ad was
offensive and not suitable to be broadcast when children
might be watching.
ASA decision – The ASA considered the ad was sexually
suggestive and might therefore be distasteful to some, but
decided that, in the context of marketing for perfume, the
ad was unlikely to cause serious or widespread offence to
most viewers. However, although the ASA considered that
the ad was unlikely to be harmful to adults or older children,
it was considered that Beyoncé’s body movements and the
camera’s prolonged focus on shots of her dress slipping away
to partially expose her breasts created a sexually provocative
ad that was unsuitable to be seen by young children. The
ASA ruled that the ad should not have been shown before
7.30 pm due to the sexually provocative nature of the imagery.
The complaint – The ASA received a complaint that it
was offensive and unsuitable to be seen by children.
ASA decision – The ASA considered that some people
would always find ads for these kinds of products
distasteful. In this case, the ASA thought the sexual
reference was unlikely to be understood by young children –
if young people did understand it, then it was reasonable
for them to see it. The complaint was not upheld.
Details of full ruling
Details of full ruling
29
Big question three:
Should advertisers have the freedom to say whatever they want?
Using industry and ASA information, students will have
opportunities to:
• engage critically with a range of advertising
• discuss topical and controversial issues
• analyse ads to examine the impact on their audience
• explore and respond to ideas and beliefs other than
their own
• speak and write to argue and persuade.
Students will explore:
• what is acceptable and unacceptable content
in advertising
• the potential to mislead or cause harm and offence
• the shock tactics often used by some advertisers
• how to bring an idea / product to the market
through advertising.
Teacher context
Advertising is part of our lives. It can inform us, amuse us
or help guide our choices. It is found in various forms –
a poster at a bus stop, an ad on the radio, an online display
ad or a spread in a magazine. Given that advertising is all
around us, it is perhaps no surprise that some advertisers
will sometimes try to grab our attention by deliberately
using shock tactics to startle us with graphic imagery or
blunt slogans.
Shock tactics are often used by charities, governments
and campaign groups to raise awareness of a cause
or to raise funds. They have been used variously in the
past to urge drivers to use their seatbelts, promote safe
sex, raise awareness of racism and other injustices,
or discourage smoking. They have also been used for
commercial purposes by some very well-known brands
such as Benetton, French Connection and Dolce &
Gabbana. All types of shock advertising have led people
to complain to the ASA.
The use of shock tactics raises an interesting question of
how far it is justifiable to push the boundaries. Are our
views different if the approach is used to advertise a “good
cause” rather than for commercial gain? We can explore
with students whether and how a diverse and democratic
society should “manage” or “police” harm, offence and
social responsibility in advertising.
Harm and offence rules (non-broadcast)
Harm and offence rules (broadcast)
30
Big question three: Should advertisers have the freedom to say whatever they want?
Lesson one: What are the limits?
1 hour
Objectives
• Should they be able to attach any image they want
to any product or service?
• To consider the divide between the acceptable and
unacceptable in advertising.
• As long as it attracts attention, is it OK?
• To explore advertising rules aimed at controlling the
likelihood of causing harm and offence.
Activity one: Shock tactics –
Valid or not?
Step one 5 mins
Starter
Use the PowerPoint slide “What are
the limits?” (BQ3 / Resource 1). The slide illustrates a
complaint considered by the ASA and found to breach
codes relating to harm and offence.
Show the slide with the image only. Let students
consider the question:
• What is being advertised here?
Click to reveal UlsterTrader.com (which is a used car
sales company).
• Is this ad OK?
Step two 5 mins
Debrief
The ASA said:
Q/A
Where should the line be drawn?
If advertisers want to stand out from the crowd and
attract our attention should they be able to push the
boundaries by using shock tactics?
“This was a poster ad. 44 complainants challenged
whether the poster was offensive, because it objectified
women, degraded them and was sexist. Some
complainants also considered that the poster implied
that women, like cars, were commodities to be bought
and sold.
Do your views change according to who is using the
approach? Consider commercial companies trying to
sell goods or services and perhaps charities trying to
promote a good cause.
We agreed with the complainants that the image of
the woman’s cleavage coupled with the strapline ‘Nice
Headlamps. What do you look for in a car?’ was likely
to be seen to objectify and degrade women by linking
attributes of a woman, her cleavage, to attributes of a car,
the headlamps, in a way that would be seen to imply a
woman, like a car, was to be ‘selected’ for those attributes.
In this exercise, students will have the opportunity
to consider some of the ethical issues raised by
advertising, using ads that have been complained
about to the ASA.
Q/A
We concluded that the poster had caused serious
offence to some readers and was likely to cause
widespread offence.”
Raise the questions:
Do students agree with the ruling?
• Should advertisers be able to use whatever images
they want?
Step three 5 mins
Link
Step four 25 mins
Using either the examples given on BQ3 Resource
sheet 2 or examples from the Ad banks, select a range
of ads appropriate to your group. The ads provided
are taken from a range of media – TV, press, poster
campaigns – and are from both commercial and
non-commercial organisations.
Tell students they are going to explore further some of
the moral dilemmas raised by pushing the boundaries
in ads. Is it sometimes justified to shock or offend to
provoke discussion or gain attention?
Continued...
31
Big question three: Should advertisers have the freedom to say whatever they want?
Using the template on BQ3 / Resource sheet 3, copy
enough sets of the materials to allow one ad per pair
of students.
• In their pairs, students are asked to study their ad
and record their responses to the questions on the
inner boxes, then the outer boxes. Student 1 can
complete the left of the sheet; Student 2 can complete
the right side.
• Once they have completed this, they should then try
to identify links between the inner and outer boxes,
drawing lines between linked points. For example “I
see a person with a fishing hook through their cheek.”
“The ad wants me to relate smoking to being hooked
or trapped.”
• When students are ready to move on, they swap their
annotated ad with another pair. They review the new
ad and the comments on the sheet they have just
received, then add any additional points of their own.
• Pairs can continue to swap comments until they have
seen either a selection or all of the ads chosen.
Step six 5 mins
Plenary
Step five 15 mins
Debrief
Q/A
• Are shock tactics an acceptable way of cutting
through the amount of advertising around us and
getting our attention?
Q/A
Who has ad A in front of them? Describe the content.
• Student 1 – Were there any links you could make
between the content and the advertising rules?
• Student 2 – What were the links between your feelings
and the intentions of the ad?
• Repeat to take comments on all of the ads used.
• What are some of the dangers of using shock tactics?
Would we become desensitised? Will ads have to
become more extreme to gain our attention?
• Why would some organisations try to court this
kind of publicity?
• Would complaints upheld by the ASA damage
the organisation’s reputation?
• Is there always a clear link between the ad content,
the ad intention and possible offence?
Lesson two: Developing an ad campaign
1 hour
Activity one: Developing an
ad campaign
• To make judgements on appropriate content and the
placement of ads.
Objectives
Step one
Task outline
They must think about the purpose of their ad, the
audience for their ad, and the context in which it will be
seen. They must also consider the brand image of the
charity / cause they will be working for.
Tell students they have been asked to plan, develop
and produce an ad for a leading national charity or
social cause.
See BQ3 Resource sheet 4 for a student guidance sheet.
• To apply knowledge and understanding to the process
of developing an effective ad campaign.
• To research the aims and objectives of a leading
national charity or topical social cause.
• To develop a presentation pitch for their finished ad.
The ad may be for a magazine, newspaper, billboard,
web page or for new media. Alternatively, they can
produce a storyboard for a television ad.
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BQ3 Resource sheet 2 teacher notes
Lesson one
Activity one: Shock tactics – Valid or not?
Teacher notes
NHS Stop smoking poster
and TV campaign 2007
Barnardo’s child poverty
campaign 2003
Paddy Power gambling
poster campaign 2005
The ASA received 774 complaints
about this anti-smoking TV and
poster campaign. The Department of Health campaign was
designed to encourage people to give up smoking in the
run-up to the ban on smoking in public places. People
thought the ad was distressing and offensive to adults and
unsuitable to be seen by children. The ASA considered that
the ads were suitable to be seen by adults, but agreed with
complainants that they were not suitable for young children.
The ASA therefore upheld the complaints about the ads
appearing in untargeted media, such as a poster. It did not
uphold the complaints about the TV ads and other targeted
media, because the advertiser had taken steps to make
sure the ad would not be seen by young children.
The ASA upheld three complaints about
this Barnardo’s press advertisement which
formed part of a national campaign.
Seven complaints were made
about this poster for a gambling
company, which showed a pastiche of Leonardo da Vinci’s
painting “The Last Supper”. The “Jesus” character was
seated behind a stack of gambling chips and the “Apostles”
seemed to be playing cards or roulette. The complainants
objected that the poster was offensive.
(N.B. The ruling for this ad is more than five years old and
no longer appears on the ASA website.)
The claim that “poverty ... is likely to lead him to a future
of squalor” was challenged because it implied most babies
born into poverty led a life of squalor.
The advertisers said the term “squalor” was used to
describe the vast array of substandard housing many
families living in poverty were forced to endure, which
included homelessness, temporary accommodation and
rough sleeping.
However, the ASA considered that the use of the term
“squalor” implied filthiness, dirtiness and grimness, not just
substandard accommodation. And that the image of a
cockroach in a baby’s mouth emphasised that interpretation
and implied most children born into poverty would live
in filth and dirt at some point in their lives. Therefore, the
ASA concluded that the claim was misleading.
The ASA considered that the representation of the Last
Supper as a casino, with the familiar Christian imagery
replaced with items used for gambling, could cause serious
offence to people of a Christian faith, and banned the ad.
(N.B. The ruling for this ad is more than five years old and
no longer appears on the ASA website.)
(N.B. The ruling for this ad is more than five years old and
no longer appears on the ASA website.)
33
BQ3 Resource sheet 2 teacher notes
Lesson one
Activity one: Shock tactics – Valid or not?
Teacher notes continued
Belle D’Opium perfume
TV ad, 2011
Diabetes UK press and
poster ad, 2009
One of two press ads
for Ryanair Ltd, 2012
The ad featured a woman dancing, whilst
pointing to her inner elbow and running
her finger along the inside of her forearm.
The voice-over stated “I am your addiction, I am Belle
D’Opium. The new fragrance by Yves St Laurent.” Thirteen
viewers complained the ad was irresponsible and offensive,
because the woman’s actions simulated drug use.
The campaign attracted 16 complaints
that it was distressing to children who
had diabetes or knew their parents had
the condition. They also found the ads’
appeal to fear and focus on the negative
impact of diabetes offensive.
The ads attracted 17 complaints from the
public that they were sexist and objectified
women, particularly female cabin crew,
and were offensive and unsuitable for
display in a national newspaper. The ASA
considered that most readers would interpret these images,
in conjunction with the text “RED HOT FARES & CREW!!!”
and the names of the women, as linking female cabin crew
with sexually suggestive behaviour. It considered that
the ads were likely to cause widespread offence, when
displayed in a national newspaper, and therefore concluded
that they breached the Code.
The ASA agreed with viewers that the ad was socially
irresponsible and unacceptable for broadcast, because
the woman’s actions simulated drug use, and upheld
the complaints.
Full discussion and ASA decision
The ASA did not uphold the complaints because it
considered that consumers were likely to infer that the
ads were primarily targeted at people who might be at
risk of developing illnesses or conditions because they
had diabetes without knowing it, or at those who knew
they had diabetes but were unaware of how serious the
potential dangers could be.
Full discussion and ASA decision
Although there was an appeal to fear in people with
diabetes who were unaware of the potential dangers
of their condition or who led unhealthy lifestyles, and in
people at risk of developing the condition, this was justified
because it encouraged prudent behaviour: diagnosis and
proper management of diabetes.
Full discussion and ASA decision
34
Lesson one
BQ3 / Resource sheet 3 student template
Activity one: Shock tactics – Valid or not?
Why might this ad break advertising rules?
What is the advertiser’s purpose?
What can I see in this advert?
How does this make me feel?
Title
35
BQ3 Resource sheet 4 student sheet
Lesson two
Activity one: Developing an ad campaign
Objectives
Step by step
• To apply knowledge and understanding
to the process of developing an effective
ad campaign.
1. Identify the charity or social cause you
will be working for.
• To research the aims and objectives of a
leading national charity or topical social cause.
2. Research their aims, their branding and
any existing campaigns.
• To make judgements on appropriate
content and placement of ads.
3. Identify the purpose of your ad.
• To develop a presentation pitch for your
finished ad.
4. Identify the audience you will be targeting.
Task outline
You have been asked to plan, develop and
produce an ad for a leading national charity
or social cause.
The ad may be for a magazine, newspaper,
billboard, web page or for new media. Or
alternatively, you can produce a storyboard
for a television ad.
You must think about the purpose of your ad,
the audience for your ad, and the context in
which it will be seen. You must also consider
the brand image of the charity / cause you
will be working for.
5. Decide which form your ad will take.
6. Choose the right media language so that
it fits the aims and image of the charity
and the intended audience.
7. Decide when and where you will want
your ad to be seen.
8. What advertising guidelines will you have
to consider and apply to your ad?
9. Prepare a presentation of your ad for the
marketing team of your chosen cause.
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Author: Genevieve Barlow
Designer: Paula Sayer
Project Management: Magenta Project Management Ltd, 01353 741222
© Advertising Standards Authority 2012
Advertising Standards Authority
Mid City Place
71 High Holborn
London WC1V 6QT
Telephone 020 7492 2222
Textphone 020 7242 8159
Email [email protected]
Online www.asa.org.uk
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