ASA - Advertising to children: Inappropriate targeting

Will an age warning be enough if placed before a scary ad?

The facts

The ASA has ruled on four ads shown on YouTube for Hutchison 3G UK Ltd (ie the mobile phone operator, Three):

• a main ad which opened with the text “Warning the following film contains scenes of a disturbing nature. Viewer discretion advised. Restricted. Suitable for viewers aged 15 and over”. It featured the 15 classification
• a banner ad (which appeared on YouTube for one day only) and two pre-roll ads which contained materials from and linked to the main ad. These started with the words “click to watch, if you dare” before the link to the main ad, which included the warning.

Although the main ad did not contain acts of violence, it could be described as scary as it contained scenes such as walking in the woods in the dark, a voodoo doll, a black shadowy figure, a haunted house and a child with “black gunge” dripping from its mouth.

The ASA received three complaints from the parents of children aged 5, 10 and 12. The complaints included allegations that: the main ad was irresponsible and likely to cause fear and distress to children who saw it; the banner ad had not been responsibly targeted because it was accessible to children; and the pre-roll ad had not been responsibly targeted because it appeared before a video which was likely to appeal to children (a Minecraft video).

The decision

•  The ASA upheld the complaints. Despite the warnings, the ads had not been appropriately targeted:
• While the main ad’s content was not excessively shocking for viewers who were 15 years old and over, younger viewers were likely to be distressed by some of the “scary” scenes.
• Even though the ads all had warnings over its content, Three needed to take greater technical steps to reduce the likelihood of the ad being served and shown to younger viewers. While
  Three had taken steps to target the ad, the ASA concluded nevertheless that it had not been targeted appropriately.
• The banner ad could not be subjected to any means of targeting as it was served to all users (regardless of whether or not they had signed into their account) on the day it appeared on YouTube. In that context, the phrase “click here if you dare” and the warning which appeared after users clicked through to the main ad were insuffcient to prevent users under the age of 15 from continuing to watch the main ad.
• The pre-roll ads were featured before the Minecraft gaming content, and Minecraft was likely to be of particular interest to children, although not exclusively directed as such. As such, the “click if you dare” language and the warning before the main ad was inadequate to deter young children. Although Three had identified and restricted content before which the pre-roll ad should not be shown, the ad still appeared before a video that was highly likely to appeal to young children.

Why is this important?

This ruling underlines the requirement for advertisers to take steps to reduce the likelihood of ads with potentially disturbing content being served and shown to younger viewers on YouTube and similar platforms.

Any practical tips?

The core problem here seems to be that the ad appeared before a Minecraft video. The ASA’s references to the “targeting” of those who have declared themselves of a certain age is concerning. This feels like a new approach and one we hope the ASA doesn’t return to any time soon.