Written evidence submitted by Advertising Association (MISS0037)

About the Advertising Association

1. The Advertising Association is the industry body representing all the advertising and marketing sectors. We are separate from the ASA, which is the regulator. The ASA is giving separate written evidence.
2. Our mission is to promote the role and rights of responsible advertising and its value to people, society, businesses and the economy. We bring together companies that advertise, their agencies, the media and relevant trade associations to seek consensus on the issues that affect them.
3. The membership of the Advertising Association is very broad and includes the associations representing industry sectors, such as the advertisers (through ISBA), the agencies and advertising production houses (through the IPA and APA), all the media (from broadcasters and publishers, cinema, radio, outdoor and online), market research (through MRS) and marketing communications services such as direct marketing and data analytics, as well as promotions.
4. We develop and communicate industry positions, and publish industry research through advertising’s think-tank, Credos, including the Advertising Pays series which quantified the advertising industry’s contribution to the economy, culture, jobs and society, as well as three publications on portrayal of people in advertising:

• Pretty as a Picture, 2011, looking at teenage girls’ views of body image in advertisements;
• The Whole Picture, 2012, looking at different ethnic views and their views on advertising portrayal.
• Picture of Health, 2013, looking at the views of teenage boys about advertising.

These were produced as part of discussions with the Government, Parliament and NGOs about the issue of body image in advertising and its effect on society.

5. Please contact us for further information on any of the points raised in this submission.

Executive Summary

6. Of the many groups involved in the body image debate, the advertising industry has been proactive in engaging with the issue and considering its role and responsibilities. In particular it has been at the forefront of improving practices and standards and it remains committed to an open and constructive dialogue with Government and other stakeholders.
    
7. Body image is a complex issue and causes of poor body image can be attributed to a number of factors. Whilst we would argue that advertising is not the sole cause and that the are many dimensions to this problem, we do recognise that certain depictions of beauty historically used in advertising may have contributed to or exacerbated issues surrounding body image. Advertising and media images can also have a wider influence and impact on people’s views about themselves and other people. That said advertising trends do change rapidly. More campaigns reflect current societal norms, whilst advertisements from the 60’s, 70’s, and 80’s, for example, would not always be acceptable to people today.

8. The industry has benefitted from more diverse approaches and advertising rules have also adapted to cement these standards. The ASA conducted extensive research around depictions of people in advertising a few years ago and this led to new Advertising Code rules on gender and stereotyping. The industry was fully involved in that process which has been instructive in informing creative approaches. Social and consumer expectations have also changed particularly as markets have diversified and extended reach. Apart from the moral and ethical obligations around promoting positive body imagery, brands understand that it makes good business sense.

9. The Advertising Association has also responded to public concerns. It was felt that to develop a better understanding of the issue required thorough research on consumer viewpoints on portrayal. This led to the three publications we mention above:  Pretty as a Picture, The Whole Picture, A Picture of Health. Education formed a centrepiece of our approach and we held seminars to inform the wider industry about those findings. We discussed with the IPA (the Institute of Practitioners in Advertising) the integration of the research findings into their CPD training programme. It also became a core module within our flagship Media Business Course, run by the AA for industry practitioners who are in the first five years of their career in advertising.

10. Finally, we would like to highlight the work of Media Smart. This is the industry’s not-for-profit initiative that provides online educational resources to teachers, helping children (7-16 year olds) with their digital and media literacy skills and to understand about advertising. Resources produced by Media Smart and taught across the country have included specific topics on influencer marketing and body image.
     

Media

What is the effect of the following on people’s body image when using social media?

Advertisements, user-generated content (posts from friends and celebrities), content promoting diet culture and eating disorders, and content promoting plastic surgery.

11. Social media advertising must comply with the CAP and BCAP Codes of Advertising Practice. The ASA rulings are decided on the basis of these Codes.  They include rules on body image and stereotyping, as well on diet supplements, weight loss and plastic surgery, as explained later in this submission.

12. Social media sites such as Instagram allow users to curate their feed by following friends, celebrities, and influencers. Thus, the experience of different users will vary greatly depending on who they choose to follow. This allows for a diversification of received content.

13. The evolution of influencer marketing has allowed for a democratisation of fame, which has led to greater diversity of individuals in the public eye. Social media users can accumulate a large following by appealing to certain niches, demographics, or the general public. Influencers can then be paid to advertise products (as long as they abide by the advertising rules which require this to be disclosed to their followers, often through ‘#ad’). This allows for consumers to be advertised to by individuals whom they choose to follow, thus the body image they are presented is a choice of the follower, rather than simply the brand.

14. This is a relatively new and rapidly evolving form of marketing communications and the ASA, with its European sister organization, EASA, has developed new industry guidance and training so as to raise awareness of the new rules.
     

What are the responsibilities of companies and the media in ensuring diversity in the images we see?

15. One of the biggest risks to a company’s reputation is a tone-deaf advertising campaign[1]. For example, Pepsi faced a social media backlash following its advertisement featuring model and social media personality Kendal Jenner[2] and pulled the advertisement within 24 hours.
16. Social media has played a role in changing how brands view diversity. Social media has allowed different communities to connect and coalesce.  Social media has given a voice to consumers and activists publicly to shame insensitive or politically-incorrect commercial messaging. Aside from the ethical and social responsibility around diversity, not being diverse is bad for business.

17. The Advertising Association recognises the importance of diversity in advertising, both in the images that we see and behind the scenes in terms of the people who work in the industry. A diverse workforce can improve an organisation’s ability to broaden its thinking and appeal, improve market share and avoid group-think. An inclusive workforce has huge benefits to an organisation’s ability to recruit and retain talent.
18. The IPA publishes an annual survey on agencies detailing the breakdown of the make-up of agencies within their membership. The 2019 report was a mixed picture compared to the previous year, but the overall trend is positive. There was a recognition that more can be done at the C-suite level.
19. The Advertising Association has an industry action plan aimed at restoring public trust in advertising.  One of the commitments is to champion more diversity. As part of this, the AA, working with ISBA (the advertiser body) and the IPA (the agency body) have launched an inclusion hub. The hub, called Advertising Needs You, features work on best practice in campaigns, recruitment, retention and recognition schemes across the industry better to reflect the UK population and to facilitate equal opportunities both behind the scenes and in front of the camera. Later this year the AA will be looking at industry progress on diverse representation.

20. Creative Equals, a non-profit consultancy dedicated to improving diversity in the creative industries, has recently launched a ‘COVID-19 inclusion pulse tracker’ to mitigate the disproportionate effect of lockdown on protected groups and ensure that diversity remains a business priority during the crisis.

Which advertisements or campaigns have had a positive or negative impact on body image? 

21. Advertisements are the result of creative ventures and impact can vary based on the individual. The standards upheld by the ASA aim to ensure that advertisements do not mislead, harm or offend, and that they are socially responsible. Campaigns which have violate the CAP and BCAP Code, including those which may contribute to negative body image through stereotyping, presenting overly enhanced images as realistic, or glamorising unhealthy body types or cosmetic surgery, can be removed.
22. An example of an advertising campaign that had a positive impact on body image was Dove’s Campaign for Real Beauty that was launched by Unilever in 2004. The key features of this campaign were that it featured real women, how they were portrayed in real life and it tries to help girls to build body confidence and self-esteem[3].
23. H&M’s “She’s a Lady” was another campaign which celebrated a diversity of women that normally would not be portrayed on screen and tried to update an outdated viewpoint of women by subverting the original meaning behind the 1970’s song “She’s a Lady” popularised by Sir Tom Jones[4].
24. Sport England’s “This Girl Can” tried to address the fear of being judged which is the primary barrier for women participating in sport. The advert was backed by a social media community which sent encouraging tweets to those who had tweeted themselves their intention of taking up exercise or going to the gym[5].

Regulation

What strategy should the Government take to encourage healthy body image for young people?

25. The existing laws are clear. The Audiovisual Media Services Directive requires that audiovisual commercial communications shall not: (i) prejudice respect for human dignity; (ii) include or promote any discrimination based on sex, racial or ethnic origin, nationality, religion or belief, disability, age or sexual orientation. These principles are also codified in the CAP and BCAP Advertising Codes.
26. Where we see a key role for Government is facilitating further research and education, specifically media literacy, for young people. This would complement the existing and important informational role that industry stakeholders have in educating the wider industry and adopting better standards. Mental health issues among school children is rising[6] and we know that low self-esteem can affect educational outcomes[7].
27. The Equalities Office could also take a lead in bringing stakeholders together to discuss issues and perspectives, as it did in the Coalition years, when there were a series of roundtables led by a Minister with different industries and campaign groups.   The Equalities Office had previously conducted some important research under the Government’s Body Confidence Campaign from 2010 – 2015[8]. We think existing body of work could be built upon.
28. This toolkit included body image resources created by Media Smart. Media Smart is the advertising industry’s not-for-profit body which provides online educational resources to teachers, helping children (7-16 year olds) with their digital and media literacy skills and to understand about advertising. Their work has been previously commended in the Government’s response to the Internet Safety Strategy.
29. The Equalities Office welcomed the focus on an under-researched area at that time: boys’ views of advertising and social media and their self-esteem. The Media Smart resources were created with the insights from the Picture of Health research published by the industry think-tank, Credos.
30. The Media Smart resources – the Boys’ Biggest Conversation – concentrate on boys, their body image and the effect it has on their mental wellbeing. The campaign features a film which includes contributions from boys talking about their perceptions of body image. It also features youth specialist Dr Ranj Singh and psychologist Emma Kenny. The campaign was produced in partnership with the NSPCC and Childline.

31. All of Media Smart’s activities are developed, co-created and reviewed with practising teachers and experts such as the PSHE Association. Media Smart resources have been downloaded 50,000 times since 2015 and reached over half a million young people in the UK. Teachers have reported that Media Smart resources are curriculum relevant, age appropriate, engaging and easy to deliver. Over 80% believe their students are better at interpreting advertising and media having been taken through Media Smart’s resources.
32. The work done within the industry, by the ASA, with schools, and in partnership with Government has led to significant progress over the past ten years in improving representation and diversity and addressing body image issues. While issues in this area are by no means solved, this work has provided a strong foundation which can be further developed. 
33. The Advertising Association recognises that body image is an important and complex issue without a simple, single legislative solution. Government policy should seek to build upon existing initiatives through partnerships with NGOs, industry, and the ASA to advance and improve upon existing programmes, industry codes and resources. 

What is the role of the Advertising Standards Authority (ASA) in promoting diversity and a positive body image in:

Non-broadcast advertising: websites, social media, emails etc;

Broadcast advertising: TV and radio

34. The ASA, as the industry regulator for advertising content, has an important role in promoting diversity and positive body image by preventing or taking down advertisements that either perpetuate or promote stereotypes or certain ideal body types.

35. The ASA assesses complaints against the CAP Code which has rules about portraying certain 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. In particular, advertisers must ensure that models who feature in advertisements are not depicted in a way which makes them appear underweight or unhealthy.
36. On 14 December 2018, CAP announced the introduction of a new rule on gender stereotyping in advertisements. These rules essentially forbid advertisements from containing gender stereotypes that are likely to cause harm, or serious or widespread offence.
37. Similar rules exist for broadcast and are administered under the BCAP Code. Clearcast has an important role in pre-vetting ads against the  BCAP rules before those ads are aired.

How successful is the ASA at protecting the public from advertisements that have a negative impact on body image?

38. The ASA has frequently ruled against advertisements which could mislead the public, lead to harm, or are not socially responsible. This includes adverts which could have a negative impact on body image - such as ads which depict models as unhealthily thin (Drop Dead Clothing Ltd, 09 November 2011), ads which trivialise plastic surgery and depict it as aspirational (MYA Cosmetic Surgery, 17 October 2018), adverts which portray protected groups in an objectifying or offensive manner (Paddy Power, 16 May 2012), and those which imply that the results of edited images can be achieved through makeup (Rimmel, 19 April 2017).

39. The ASA uses monitoring technology to identify and remove problem ads on social media. This technology has recently been used to crack down on advertising for Botox and other botulinum toxin injections on social media platforms.

40. As well as enforcing the CAP/BCAP codes, the ASA provides a plethora of guidance and resources for advertisers on how to go beyond simple adherence to the codes and advertise in a socially responsible manner.

41. The ASA also carries out in depth research into harm and social responsibility within advertising, with final reports made publicly available. Examples include: Depictions, Perceptions and Harm (on gender stereotyping) and Research on the Labelling of Influencer Advertising.

June 2020

References