Examination of Witnesses (Question Numbers
500-519)
MR GUY
PARKER AND
MS KATE
STROSS
2 JULY 2009
Q500 Mr Scott: Maybe you are correct
about specific advertising, but do you agree that to a certain
extent it has become a lot cleverer and a lot more is directed
to sponsorship where every activity to which young people would
look—football, rugby and so forth—is sponsored by
drinks companies? Is it not still at the forefront whether or
not they see it on TV?
Ms Stross: The rules on broadcast
sponsorship are effectively the same as those that apply to broadcast
advertising. If you are not allowed to put alcohol advertising
around a particular programme because it is particularly attractive
to or made for young people you are not allowed to sponsor it
as an alcohol advertiser either. If you cannot advertise you cannot
sponsor. There are also rules around broadcast sponsorship; it
must not contain overt selling messages. There is clear regulation
of sponsorship as well as advertising on television.
Q501 Mr Scott: Last week The Lancet
referred to evidence that a lot of the content of drinks adverts
had an effect on young people. I can think of a number just off
the top of my head without referring to particular companies and
ads. They are aimed specifically at younger people, so the rules
are not working at the moment, are they?
Ms Stross: I am afraid I am not
familiar with the article in The Lancet to which you refer,
but all advertising is subject to the rules.
Q502 Mr Scott: The question is: do
you think those rules are being adhered to?
Ms Stross: If they are not I presume
that the ASA would be receiving complaints about them and dealing
with them.
Mr Parker: I talked a couple of
times about the compliance rates, which are high. The system is
not perfect and from time to time ads break the rules. In the
past few years we have put a lot of effort into ensuring the industry
understands the stricter rules introduced in 2005. There is a
little bedding-in time. Sometimes we wish that was not the case
but that is the reality we face. I do not accept or understand
the conclusion that a lot of ads are aimed at young people. That
is not what we find when we look at representative samples of
advertising.
Q503 Chairman: Ms Stross, though
it may not be your direct responsibility have you ever looked
at the level of advertising for drinks that appeal to young people,
for example white ciders and products like that where the unit
costs are very low and they are consumed by people who have what
we call problems? Have you ever looked at whether such things
are advertised more than other forms of alcohol?
Ms Stross: The amount of money
spent on advertising on TV has been fairly steady over the past
several years.
Q504 Chairman: I am looking at the
products that potentially cause antisocial behaviour in society
and clearly pose a threat to the health of the individual concerned.
Ms Stross: Within a steady total
you certainly get increases and decreases in the amount of advertising
of particular kinds of drinks. You may perhaps be referring to
cider advertising on TV which increased considerably and fell
back a little in 2008 after a big spike in 2007. One sees cycles
driven by fashion or perhaps a particular company's decision to
put a big marketing spend behind its product.
Q505 Dr Stoate: I would like to refer
to a recent evaluation that you carried out or was carried out
on behalf of ASA and Ofcom into the new controls on ads focused
at young people. That evaluation says that "there has been
no change in how much young people say they like the adverts and
there has been an increase in those saying the adverts make the
drink look appealing and would encourage people to drink it."
Is that a success or failure?
Ms Stross: To give that a little
bit of context, when that research was undertaken by the ASA and
Ofcom we specifically looked at the ads we felt were at the margins
of acceptability under the rules. The ads that we evaluated in
the research sessions with young people were not a random sample
of television alcohol advertising. They were particularly at the
"edgy" end and you must place the results in that context.
Having decided to use that research methodology, when we did the
second wave of research we found it was more difficult to find
"edgy" ads than it had been when we did the research
before the rules were changed, which I think is reflective of
the fact that the tightening of the rules have had some effect.
What young people said to us was that while they might find the
ads interesting or amusing and they could encourage people to
drink they were less likely to say that the ads were targeted
at them. Like all qualitative research you have to look at the
thing in its entirety, but we were deliberately researching the
potentially more problematic advertising on TV.
Q506 Dr Stoate: I accept that, but
in your written submission you describe the findings of the evaluation
as "positive". Surely, that cannot be seen as a positive
contribution to public health.
Ms Stross: We were using "positive"
in the sense we felt the rule change had been effective. I am
not sure we were evaluating the effect of the rules on public
health.
Q507 Dr Stoate: I am still not sure
how you can say the rule change has been effective when there
has been an increase in the number of people who think that ads
make the products look appealing and would encourage people to
drink them. I am slightly confused about how that can be seen
as a success.
Ms Stross: The point is that the
young people we were specifically talking to in the research did
not feel the ads were targeted at them, so they were talking slightly
more hypothetically about the effect the advertising might have
on other people and believed it was less focused on themselves.
Q508 Dr Stoate: But to say that it
was not aimed at them but they found them rather good is a specious
argument. I do not quite see the distinction.
Mr Parker: I think there is a
distinction between saying you think an ad will make you drink
more and saying you think an ad may make the audience of the ad
drink more. In our research there were certainly results that
caused us to stop and think. Those two particular responses from
young people were the key ones that made us stop and think and
ask ourselves whether we had got that bit of it right, but the
research covered a lot else. We took some reassurance from the
fact that for the under-18s who responded to the question, "Are
the ads aimed at people like me?" the net score was reduced
from -11% to -33% which is a big reduction. For the two findings
you mentioned about which we were not so happy the net scores
for the under-18s increased from 22% to 29% and from 21% to 26%.
I believe those are statistically significant increases. That
was what caused us to think whether we needed to do more here.
We did not go into the post-research knowing what the results
would be; there is no point in doing research if that is the case.
We learnt from it. We had extensive discussions about it with
the ASA council and asked ourselves whether we were always getting
it right when we adjudicated on cases. In the past year or two
we have taken some decisions that maybe we would not have arrived
at prior to the emergence of the 2007 research. I do not know
whether you have the figures, but I can certainly share them with
you. As to the number of ads and campaigns we have upheld against,
there were rather more in 2008 than in the previous two or three
years. One must be very careful about saying that is caused by
our reaction to the 2007 research. As always, there are lots of
factors that may have affected it, but it probably did play a
part in it.
Q509 Dr Naysmith: In that same research
report you talked about "kiddult marketing" which "blurs
the fixed lines between adults and children". Do you think
the current regulations protect children from "kiddult"
advertising?
Mr Parker: I think the rules do
and that our interpretation of them does so. It is very often
all in the interpretation. That is why the 2007 research, the
other research that is around and our feedback from consumer events
and other engagements we have with the public are so useful. It
gives us a better handle on whether we are getting the balance
right and drawing the right conclusions. We are very careful to
ensure that ads do not have youth appeal and contain elements
that reflect youth culture. It is never a black and white situation.
Very often these decisions are not easy to come to because there
are quite good arguments on both sides, but we have an undoubted
tradition of interpreting these rules strictly. What I am really
talking about are varying degrees of strictness. If you spoke
to those in the industry—I daresay you will in future sessions—they
would corroborate that. Quite often they take issue with the specific
decisions that we reach because they think we are being overly
strict even though they are generally supportive of self-regulation.
Q510 Dr Naysmith: It must be a particularly
difficult when you have to avoid links to youth culture and sporting
success with alcohol sponsorship of music festivals such as T
in the Park and premiership football. You said there had been
a 30% reduction in the amount of advertising that young people
see on television, but does that include the names of drink companies
on footballers' shirts and things like that?
Ms Stross: No.
Q511 Dr Naysmith: That could represent
an increase while at the same time there is a reduction in direct
advertising?
Ms Stross: That is theoretically
possible. My statistic referred to the number of occasions on
which one young person sees an alcohol ad. That has certainly
dropped, but I do not have the measurements for either sponsorship
or the kind of thing to which you are referring, for example where
somebody wears a football shirt with a logo on it. That kind of
sponsorship exists entirely independently of the broadcast world;
that is football team sponsorship.
Q512 Dr Naysmith: But there is quite
a lot of football broadcasting nowadays. We see these ads when
matches are broadcast.
Ms Stross: That is true. It is
not an area that we are able directly to regulate. That is the
regulation of football rather than TV broadcasting.
Q513 Dr Naysmith: It is not within
your purview because it is not direct broadcasting, but do you
measure that?
Ms Stross: I do not know of a
way to measure it. It would be extremely difficult. Not only do
you have to measure how much there is but how much it is watched.
There are precise systems to do that with advertising.
Q514 Dr Naysmith: It would be really
interesting to try to measure whether or not it had any effect
but you cannot do that.
Ms Stross: In a sense that harks
back to the point made by the ScHARR report. It is very difficult
directly to link promotion to consumption effects. That link is
more difficult in the case of advertising and promotion than it
is with price.
Mr Parker: There is a limit to
my knowledge on sponsorship for the simple reason that the codes
do not cover such arrangements. They cover advertising for sponsored
events and they are subject to the same rules that apply to other
ads, but I know a little about the European Sponsorship Association
because it is a member of the European Advertising Standards Alliance.
It joined relatively recently. I think it has recently published
a survey on alcohol sponsorship which is available on its website
and you may find some of the answers you seek there.
Q515 Dr Naysmith: How effective do
you think the current controls are on internet and viral advertising?
Are there controls that work?
Mr Parker: This is for me because
predominantly it is non-broadcast advertising. We cover a fair
amount online: paid for advertising; sales promotions wherever
they appear; direct marketing emails; and viral advertising. We
do not yet cover marketing communication messages on companies'
own websites, but there are advanced discussions within the industry
looking at extending the remit of the system to cover just that.
I hope they will very soon be in a position to announce that that
will happen.
Q516 Jim Dowd: I am looking here
at a chart taken from the 2007 report to which reference has already
been made. It refers to "total alcoholic drinks commercial
impacts" and reveals a welcome decline over the period 2002
to 2006 which covers the latest figures available when the report
was compiled. I do not fully understand it. Can you tell me what
a commercial impact is?
Ms Stross: A commercial impact
is one viewer seeing one television ad. I think that the chart
you are looking at refers to viewers of a particular demographic
group—10 to 15 year-olds—so the question is: how many
times did 10 to 15 year-olds see an advertisement for alcohol
in each year?
Q517 Jim Dowd: It appears to indicate
that 11 year-olds were not exposed to these commercial impacts
as often as 23 year-olds. But there are 181 impacts for 23 year-olds
compared with 130 for an 11 year-old. Why on earth are 11 year-olds
being impacted by alcohol advertising?
Ms Stross: I think it is because
the average 11 year-old will watch some programmes that are made
specifically for children where you would not find alcohol advertising,
but they also find the same programmes appeal to them to some
extent as appeal to people in general. Therefore, I presume that
the 130 impacts to which you refer are ads that they see in and
around programmes that are not targeted specifically at young
people but are popular with the general audience.
Mr Parker: That is the reason
why ostensibly there are two levels of protection when it comes
to TV advertising, first through the scheduling rules to prevent
an affinity with or association between programming for young
people and alcohol advertising. But no one is saying that that
reduces all exposure; it does not. That is why you have the second
level of content rules to deal with the fact that there is some
exposure.
Q518 Jim Dowd: Effectively, this
is collateral damage rather than grooming, for example?
Mr Parker: I do not believe I
would use those words. The content and scheduling rules come as
a package. I think that package is important given the situation
you would have in society without it.
Q519 Jim Dowd: You say there is no
ulterior motive to market alcohol to 11 year-olds; there is no
sub-text here?
Ms Stross: Advertisers are generally
responsible and comply with the rules. It is also the case that
what that chart measures is all alcohol advertising. That will
be for the full range of alcoholic drinks products some of which
will be more and some less appealing to young people. There may
be products that are advertised within that in which, frankly,
young people are very unlikely to have any interest but they happen
to see an ad for it during a programme they are watching on TV.
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