Written evidence submitted by ISBA (MISS0034)

 

About ISBA

 

  1. ISBA is the only body representing leading UK advertisers. Speaking with one voice on behalf of over 3,000 brands, we champion an advertising environment that is transparent, responsible and accountable; one that can be trusted by the public, by advertisers and by legislators. Our network of senior marketing professionals works together with ISBA to help members make better decisions for the future.

 

  1. ISBA is one of the tripartite stakeholders that make up the Advertising Association (AA), which represents advertisers, agencies and media owners. We play a unique advocacy role, ensuring our members’ interests are clearly understood and are reflected in the decision-making of media owners and platforms, media agencies, regulators and Govern-ment.

 

  1. ISBA’s goals are to:

 

•        lead our members in creating an advertising environment that delivers positive social and economic impact;

•        champion media, agency and digital supply chain relationships that deliver value for advertisers; and

•        work with our community of members and with partners to deliver thought leadership, learning, advice and guidance.

 

  1. Our priorities fall into the following areas.

 

To lead the creation of an advertising environment that delivers positive social and economic impact, ISBA will:

 

•        develop and champion a leadership position on the legal and ethical use of consumer data, putting choice and control in the hands of the consumer;

•        play a leading role in advocating and shaping regulation of online harms;

•        shape future self- and co-regulation of advertising to be sustainable and fit for purpose; and

•        with the AA, better understand the drivers of public trust and champion improvement, through the promotion of advertiser best practice, through advocacy for better industry standards and through encouraging the prioritisation of user experience by platforms and publishers.

 

To champion a media, agency and digital supply chain relationships that deliver value for advertisers, ISBA will:

 

•        lead global efforts to accelerate delivery of accountable cross-media measurement of video and digital formats, with stakeholder support;

•        lead advertisers in the pursuit of transparency and efficiency in the digital supply chain to engender trust;

•        publish new media contract advice and drive wider industry adoption of ISBA’s contract frameworks;

•        champion closer agency/client alignment based on sustainable commercial arrange-ments;

•        advocate for a regulatory environment that fosters competition and addresses market failures;

•        actively support the WFA Media Charter, particularly in relation to advertising and influencer fraud; and

•        support the Global Alliance for Responsible Media in delivering improved measure-ment and tools to keep communities and brands safe.

 

To work with our community to deliver thought leadership, learning, advice and guidance, ISBA will:

 

•        drive wider active engagement with ISBA through membership growth and greater participation in ISBA’s working groups and governance bodies; and

•        deliver an enhanced online knowledge base, working selectively with partners to create high quality, relevant content.

 

  1. ISBA represents advertisers on the Committee of Advertising Practice (CAP) and the Broadcast Committee of Advertising Practice (BCAP) – the sister organisations of the Advertising Standards Authority which are responsible for writing the Advertising Codes. We are also members of the World Federation of Advertisers (WFA). We use our leadership role in such bodies to set and promote high industry standards, as well as a robust, independent co-regulatory regime.

 

Response

 

  1. ISBA welcomes the Committee’s inquiry into body image in advertising and marketing. As one of the key stakeholders in the Advertising Association, we have strongly supported the research and development of policy positions undertaken by the AA, including the Credos reports Pretty as a Picture (2011), The Whole Picture (2012), and Picture of Health (2013), representing teenage girls’ views, the views of minority ethnic individuals, and the views of teenage boys, respectively. The industry has been a key part of discussions with national and devolved government, as well as Parliament more widely, on body image.

 

  1. We recognise the serious challenge to people’s mental and physical health which is associated with questions of body image. It is clear and obvious that advertising, media images, and programming can have an influence on people’s views about themselves, and that there are issues which can arise when individuals are shown depictions of ‘perfect’ bodies that they then either judge themselves by, or unhealthily strive to aspire to.

 

  1. The recognition of this, and advertising’s role not only in reflecting society’s changing norms but as a potential force for positive social change, drove ASA research around depictions of people in advertising, and new rules by CAP on gender and stereotyping. ISBA was fully involved in the composition of those rules, and continues to work with CAP on their enforcement, and on learnings from cases and rulings which are brought forward.

 

  1. The CAP/BCAP codes contain rules around portraying particular body types in an irresponsible manner; implying people can only be happy if they look a certain way; or presenting an unhealthy body image as aspirational. Advertisers are obliged to ensure that models who feature in ads are not depicted in a way which makes them appear under-weight or unhealthy. Clearcast, on which ISBA representatives sit, has an important role in pre-vetting advertisements against these rules and codes, before ads are allowed to air.

 

  1. We also support Media Smart, the industry’s not-for-profit initiative that provides online educational resources to teachers, helping 7-16 year olds with their digital and media literacy skills and to better understand advertising. Media Smart’s resources include packages on influencer marketing; body images; how images can be re-touched and enhanced – and therefore misleading; and how to identify adverts. At last year’s General Election, ISBA published a manifesto which called for greater efforts to teach and improve children and young people’s digital literacy, including in this area.

 

  1. We continue to be involved in the issue of body image through two of our Working Groups. Firstly, our recently constituted Influencer Marketing Working Group is currently consid-ering the design of a potential industry standard Code of Conduct, which would include commitments for brands and influencers. Obligations towards adhering to CAP code standards, especially protecting children, minors, and vulnerable adults, will form a part of this Code, which is under discussion with ISBA members.

 

  1. Secondly, our Diversity and Inclusion Working Group convenes senior members of our industry to work towards marketing and advertising communications being fully repre-sentative of contemporary society, while also leading discussions on societal issues such as body image. In doing so, it widens engagement in relevant industry initiatives, and promotes thought leadership by our members.

 

  1. As an example, we strongly support efforts to survey on-screen representation in TV advertising, in terms of diversity of representation but also to feed into conversations around issues of the kind the Committee is investigating. Channel 4’s “Mirror on the Industry” is one such survey, bringing life to the channel’s mission when established to “stand up for diversity and champion unheard voices”. The survey is a status check on the nature of TV advertising, working with YouGov to quantify how well minority groups are represented within current TV advertising in the UK, as well as seeking to understand the perception of representation amongst minority groups (and the population as a whole).

 

  1. Similarly, Lloyds Banking Group’s study, “Reflecting Modern Britain?”, looks at the state of advertising in terms of representation, in an effort to develop more inclusive advertising for brands. The study reviewed over 1,300 adverts from over 40 different brands, with the result that less than 20% of the people featured in advertisements included people from minority groups. Only 47% of people felt accurately portrayed by advertising. A key takeaway from the study was that brands should be authentic and ensure that depictions of individuals were realistic – and that there was a demand from respondents that advertisers and brands had a duty to do so, and that favourability towards them in part depended on it.

 

  1. ISBA’s Diversity and Inclusion group is also working with YouGov to poll a regular question of ‘Does this advert look and feel like me?’, with the promise of this becoming a regular checkpoint of measurement and progress towards diverse representation.

 

  1. These initiatives are of course focused to a greater degree on the representation of our diverse communities, but they are also relevant to body image in the sense of the need for authentic depictions, and for the general importance of individuals seeing themselves represented onscreen. In this vein, the industry’s Project Diamond is also relevant. This is a single online reporting system supported by all major TV broadcasters to measure the diversity of everyone on television, and everyone who makes television. Individuals involved with the production of any programme – in front of or behind the camera – are e-mailed with a link to a voluntary self-completion questionnaire. The data generated is then developed into an annual report (although the data can also be accessed on an ongoing basis, by channel, type of programme, and seniority of role).

 

  1. This live data has been immensely useful to industry in illustrating that, for example, women represent 52% of appearances on-screen and 53% of off-screen contributions, yet are missing from key senior roles (being only 26% of directors). BAME people account for 22% of on-screen appearances, yet only make up 8% of directors.

 

  1. We are currently exploring extending this data to advertising. The marketing and advert-ising company MediaCom is consulting with industry bodies including ourselves, the AA, the IPA, and the Creative Diversity Network to create a world-leading version of Project Diamond for our industry.

 

  1. Case studies from the industry illustrate the key importance of initiatives of this kind, and of the urgent imperative to tackle issues around body image. Bodyform/Libresse won industry awards for its #bloodnormal campaign, aimed at normalising and celebrating periods. A senior strategist who worked with the brand shared her own experience of period shaming as a young girl, highlighting the power that brand advertising can have in changing how body issues are discussed.

 

  1. Bodyform/Libresse followed this up with Viva La Vulva, a film and campaign aimed at education and breaking taboos – taboos which in some cases could be fatal. Global quantitative research by the brand found that more than two-thirds of women technically did not know what their vulva was, while nearly half of them had felt embarrassed by it. This has led to elective plastic surgery, or women avoiding smear tests. This was espec-ially pertinent, given recent figures around the take-up of smear tests falling to new lows in England. Bodyform/Libresse’s campaign contributed to a more open culture of dis-cussion around a body image subject, with enormous potential health benefits.

 

  1. With the transposition of the Audiovisual Media Services Directive into UK law, our legis-lation is clear that audiovisual commercial communications must not prejudice respect for human dignity; or include or promote discrimination based on protected characteristics. This imperative is codified further through the advertising codes set out by CAP and BCAP. The campaigns taken forward by brands and the initiatives promoted by industry – current and under development – demonstrate the importance which the advertising and mark-eting community attaches to addressing issues of this type.

 

 

June 2020