Advertising Standards Bureau Review of Operations 2014 - Page 50

The Board considered a number of cases which involved interactive games on advertiser websites. In determining whether these marketing communications were aimed at children, the Board found that requiring log-in details and/ or a date of birth to play the games was good practice, however this did not mean the medium was not directed primarily to children (Kellogg’s - 0033/14, Unilever - 0089/14 and Lion 0075/14). In determining whether the games were directed primarily to children the Board examined the visuals, themes and language of the advertisements. In a number of cases animated games with familiar cartoon characters were found to be directed primarily to children (Kellogg’s 0033/14, Unilever - 0089/14 and Lion - 0075/14). In 0205/14 (Nestle) the Board found an advertisement for a chocolate bar which featured animated characters and bright colours, was not directed primarily to children, but would appeal to a more general audience. The Board considered the themes in the advertisement were slightly complex and the use of adult characters and voices meant the advertisement would be attractive to older audiences. In contrast an advertisement which featured bright colours and animation, was found to be directed primarily at children because of the simple theme, and the use of only children in the advertisement (0399/14 Unilever). Elements of an advertisement Across 2014 the Board considered that: • • • 48 The use of a familiar cartoon character is not necessarily enough to determine an advertisement is for an associated product, if that product is not referenced (Unilever 0089/14 and Lion - 0075/14). Th e use of bright colours is also not enough to indicate that the advertisement is directed primarily to children as it may also be equally attractive to adults (Kellogg’s - 0221/14). The use of animation alone is not enough to indicate that the advertisement is directed primarily to children, if the tone and style of the animation is one that would be equally attractive to adults (Nestle - 0205/14). Advertising messaging Encourage physical activity Under the RCMI the product advertised must represent a healthier dietary choice and the advertising and/or marketing communications must reference, or be in the context of, a healthy lifestyle, designed to appeal to the intended audience through messaging that encourages: In 0033/14 (Kellogg’s) the Board found that an interactive game which encouraged children to pretend to play the drums, was enough to encourage physical activity: • g ood dietary habits, consistent with established scientific or government criteria, and • physical activity. Encourage good dietary habits In 0033/14 (Kellogg’s), the Board determined that the omission of any messaging about healthy dietary behaviour in an online interactive game, was in breach of the Initiative, even though the advertised product was one which met the healthy dietary choices criteria. In 0089/14 (Unilever) the Board found that messages encouraging a balanced diet were enough to encourage good dietary habits: “The Board acknowledged that there is considerable difficulty for advertisers on a website platform to reflect this type of messaging and considered that in this matter there was sufficient information around good dietary habits. The Board noted that the website, incorporates on-screen messages of “Enjoy … as a treat within a balanced diet” and “true heroes balance energy intake with activity” on every page of the website. The Board noted that the messaging is written in simplified language that could be understood by children.” “The Board noted that the activity itself of playing the game on the computer was not a game that required a lot of physical activity per se. The Board agreed that playing a real set of drums would most definitely require physical contribution. The Board considered that the game itself did not have to include intense physical activity for the player but that the message that the game was delivering was a positive message that would likely encourage children to actively get involved in playing music or imaginative games involving music and movement. The Board considered that the advertisement did encourage physical activity”. Similarly, the Board found that wording on a website which encouraged children to stop playing online and have an ‘adventure’, did amount to encouragement of physical activity (Unilever - 0089/14). The Board also determined that structured sport or exercise was not required and the image of children playing outside can meet the requirement to encourage physical activity (Unilever - 0399/14). The Board also found that, depending on context, messages that inform a user when they have been playing an online interactive game for a certain amount of time was one way to meet this requirement (Lion - 0075/14). Similarly in case 0075/14 (Lion) messaging on the site encouraging healthy eating in simple language attractive to children was enough to meet this requirement. However, the Board found that similar messaging in a television advertisement was not enough to encourage healthy eating choices, as the text was less noticeable when viewed with the movement and sound on screen (Unilever - 0399/14). Advertising Standards Bureau