Ad description
Claims on the Gatwick Express website stated "Gatwick Express is the fastest way between London Gatwick Airport and central London. Running non-stop between London Victoria station and London Gatwick Airport, our dedicated airport train is renowned for its speed and frequency. With a timetable departure of every 15 minutes, and with a journey time of just 30 minutes, Gatwick Express is the best way to get to and from London Gatwick Airport".
Issue
The complainant challenged whether the claim "Gatwick Express is the fastest way between London Gatwick Airport and central London" was misleading and could be substantiated.
Response
Southern Railway Company Ltd (Southern) pointed out that their service went to and from London Victoria, while First Capital Connect (FCC) typically went to and from London Bridge. They argued that that was an important difference because, for the majority of passengers, the rail terminus was not their final destination and they were typically travelling into central London. They said Victoria was only 1.6 miles and two tube stops from central London (defined as Oxford Circus), whereas London Bridge was three miles from Oxford Circus and four stops on the tube, including a change. They said feedback from customers who had tried all three rail options showed that customers regarded London Bridge as the least convenient gateway to the capital.
Southern said, in order to ensure that the claim that Gatwick Express was the fastest way between Gatwick Airport (Gatwick) and central London, they regularly carried out a comparative analysis of the average journey times for both Gatwick Express and FCC’s trains, in both directions between Gatwick and London.
Southern said there were 81 Gatwick Express trains from Gatwick to Victoria each weekday. They said the average journey time was 31 minutes, but that 62 of those trains took only 30 minutes. They said, by comparison, FCC operated 69 trains each weekday and the average time for those journeys was 33 minutes.
Southern said, in the opposite direction, there were 78 weekday Gatwick Express services with an average journey time of 30 minutes and, by comparison, 70 FCC services (from either London Bridge or Blackfriars) taking an average of 33 minutes.
Southern said, if the results for each direction were combined, the average Gatwick Express journey time was 30 minutes and the average for FCC was 33 minutes. They said Gatwick Express was therefore, on average, three minutes faster. They said, in addition, the fastest trains on either service, during the day were two Gatwick Express services at 17:30 and 17:45 which took 27 minutes which was less than any FCC service. Southern provided timetable data in support of those arguments and also supplied data for their weekend services and those of FCC.
Southern said that train frequency was also a factor and said, based on analysis of all Gatwick Express and FCC trains running during the most popular travelling hours in each direction the average time between trains to Gatwick was 15 minutes for Gatwick Express and 17 minutes for FCC. They said the London-bound services supplied by Gatwick Express and FCC left on average every 14 minutes and 17 minutes respectively. They argued that, because Gatwick Express services were more regular, and because passengers arriving on the station platform would normally board the first train that arrived there, they would be able to board a Gatwick Express train sooner and their service was therefore also faster from that perspective.
Southern said Gatwick Express was already passengers’ favourite mode of travel between Gatwick and the capital with approximately a 60% share of all rail journeys. They said they had also calculated the Gatwick Express loadings data from Gatwick Airport to Victoria which showed that 58% of passengers on Gatwick Express travelled at times when its journey time was faster than FCC’s and argued that that data supported the claim as well.
Assessment
Upheld
The ASA noted Southern’s argument that Victoria had a greater claim to be a central London train station because of its closer proximity to Oxford Circus. However, we considered that, without further qualification regarding the equivalent services, the claim "Gatwick Express is the fastest way between London Gatwick Airport and central London" would be interpreted by readers to mean that Gatwick Express offered the fastest train service between Gatwick and any of London’s Zone 1 train stations. We therefore considered that Southern needed to demonstrate with train journey time data that the journey times for Gatwick Express between Gatwick and Victoria were shorter than FCC’s times to the Zone 1 stations that they served.
Although we noted the ad’s reference to, and Southern’s arguments about, train frequency we considered that the claim would be interpreted as relating to the length of the journey itself, rather than how often a service might be boarded.
We noted the data provided by Southern but we also noted that that data was timetable information only and did not show actual recent departure and arrival times for both services. We therefore considered that the submitted data was not capable of demonstrating the actual journey times experienced by passengers on either service.
Notwithstanding that, we noted Southern’s argument that average journey time for their service in both directions was 30 minutes compared with 33 minutes for FCC. We noted, however, that those figures had been calculated using a mean average which did not take account of the fact that 61% of FCC’s weekday journeys took less than 30 minutes, compared with only 6% of Gatwick Express’s. We also noted that their supplied calculations had only been applied to the weekday timetable data. We noted that, when we applied both mean and modal averages (which showed the most common journey time) to all the train journeys from Monday to Sunday both services were shown to have the same average times: 32 minutes (mean) and 30 minutes (mode).
Notwithstanding our concerns about timetable data being inadequate to support the claim, we concluded that the data we had seen did not show that Gatwick Express was the fastest service between Gatwick and central London. We concluded that the claim was misleading.
The ad breached CAP Code (Edition 12) rules 3.1 (Misleading advertising), 3.7 (Substantiation) and 3.38 (Other Comparisons).
Action
We told Southern to remove the claim from their website and ensure that they held robust substantiation before making comparative claims in future.
