ASA – Gambling ads: keeping a watching brief

The ASA/CAP have released a post called: Gambling ads: keeping a watching brief. I have enclosed the text of the link below, but please have a look at the ASA/CAP site as there are lots of things of interest to anyone with an interest in Ethical Marketing.

Lockdown

In April, we warned gambling and lottery operators to uphold the highest standards in their advertising.  Lockdown had created a captive audience and there were concerns that many people facing an uncertain financial future or other anxieties caused by the pandemic would see gambling as a way out.

We’ve been keeping a watching brief over gambling ads and here’s how:

Complaints

Complaints about gambling ads have remained at pre-lockdown levels: approximately 60-100 per month, comprising 2%-3% of our annual post bag of complaints. In line with the trend, complaints remain general in nature: objecting to the fact of gambling ads, their perceived high number or children’s exposure to them (no matter that the ads were shown around TV programmes or online content attracting a predominantly adult audience). But, they rarely identified a likely breach of our rules.

We didn’t receive any reports of gambling ads unfairly referring to or directly exploiting the crisis, despite our encouragement to report any such ads, but we did take two gambling ads to task, which appeared during lockdown and broke our rules.

In July, we published a wider review of trends about ad complaints during lockdown.

 

Monitoring Online

We use a variety of means to proactively monitor ads online.

Later this month, as part of our ‘Tech as a Force for Good’ projects, we’ll publish the results of our automated monitoring activity delivering round-the-clock, CCTV-scrutiny of websites and YouTube channels disproportionately popular with children. 

We trialed the technology in the first quarter of 2020 and found, on some of these websites and in clear breach of our targeting rules, ads by the following gambling operators:

  • Jumpman Gaming Ltd t/a slotsbaby.com
  • Betfair Casino Ltd t/a Betfair Casino
  • MT Secure Trade Ltd t/a Kaboo Casino
  • MT Secure Trade Ltd t/a Rizk Casino
  • Novigroup Ltd t/a Novibet Casino
  • Skill on Net Ltd t/a playojo.com

We notified the Gambling Commission and, in each case, worked with the gambling operator to understand and address the compliance failings, which led to these outcomes. Three other gambling operators have been referred to the ASA for formal investigation following the trial. 

Gambling operators certainly don’t intend their ads to appear on websites disproportionately popular with children. And, in our experience, most operators avoid this unwanted outcome by careful management of the numerous factors and third parties involved in distributing ads online, especially programmatic ads.  

The ASA is committed to keeping this area under review to ensure children receive the necessary protection from advertising-related harms in online environments. By doing so, we’re looking to foster a culture of zero tolerance to age-restricted ads appearing on websites and YouTube channels disproportionately popular with children.

 

TV Exposure

Each year, we report on audience exposure to gambling ads and other age-restricted ads on TV. 

In May, we reported that audience exposure to gambling ads had remained at similar levels over the last six years, averaging 13.8 ads per week for adults and 3 ads per week for children (with children seeing, on average, 2.5 gambling ads per week in 2019). This longitudinal reporting is essential to getting a clear and reliable picture of exposure over time and any ‘snap shot’ exposure information, based on a short and extraordinary period of time, must be treated with extreme caution.

In August, Ofcom reported that screen time during lockdown saw people in the UK spend 40% of their day watching TV and online video services, with ITV, Channel 4 and Channel 5 briefly achieving their highest combined share of broadcast TV viewing in more than six years. 

It’s not surprising, therefore, that – in the eight weeks following 23 March, when lockdown was announced – we saw an increase in overall exposure to ads, including gambling ads, driven by changing patterns in TV viewing. In comparison to average levels over the last six years, adult exposure rose, on average, from 13.8 to 22.2 ads per week, and children’s exposure rose from 3 to 3.9 ads per week. 

Exposure to bingo and lottery ads accounted for these increases, with adults’ exposure, in the main, also being driven by an increase in exposure to gaming product ads, which are broadcast after 9pm. Not surprisingly, in a period of no professional sport, exposure to betting ads declined dramatically to almost zero!

It should be noted that following this period of reporting, members of The Betting and Gaming Council volunteered to temporarily remove all gaming product advertising on TV and radio and, with the resumption of professional sports, we’ve correspondingly seen the reappearance of betting ads, with an increasing number focusing on safer gambling messaging.

In terms of the post-lockdown picture, Ofcom reports that, as of now, broadcast TV viewing is comparably lower than it was in 2014-2017, although it remains 11% higher than this time last year. 

We’ll see whether these ups and downs in exposure, which we see every year but with less volatility – alter the annual exposure figures, which have remained broadly steady over the last six years. We’ll publish the next round of annual exposure figures for 2020 in early 2021.

 

The Rules and Guidance

Last but by no means least, we’re keeping a watching brief on our rules and guidance, to ensure they deliver necessary protections for children, young people and other vulnerable persons.

In the next couple of months, we’ll respond to GambleAware’s Final Synthesis Report on the effect of gambling marketing and advertising on children, young people and vulnerable adults and, spoiler alert, publish consultation proposals with the aim of enhance advertising protections and clarity for users of the Advertising Codes.

So, we’ve been busy in our monitoring and regulation of advertising for gambling and lottery products, perhaps especially so in the context of the coronavirus and the concerns it raises about vulnerable groups of people.

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