In response to our Harm and Offence research findings, we’ve been looking into the nature of complaints we receive about charity and public service ads and whether we’re drawing the line in the right place. As a result, we’ll now be looking more closely at ads in this sector to ensure we continue to reflect people's concerns.

Charitable causes and public service ads often highlight sensitive and sometimes upsetting subject matter. Traditionally, we’ve granted more leeway to these types of ad because of the importance of the issues they are raising awareness about. But our research has prompted us to question whether we’re getting things right.

One of the unexpected findings to come out of our research was the spontaneous concerns raised by participants who felt these ads can go too far in using distressing content to make people feel upset or guilty. Moreover, there were widespread concerns expressed about the impact of these ads on children. Indeed, many adults objected to hard-hitting charity ads appearing on designated children’s TV channels.

Crucially, children themselves mentioned charity ads as those which had upset or bothered them or younger siblings recently.

We established an internal working group to look into this further; undertaking various measures to establish whether our existing approach to judging complaints reflects prevailing public opinion.

The steps we’ve taken include:

• Analysing complaints data and our decisions between 2010 – 2013 to see if there were any trends and whether complaints tallied with the sentiments expressed by participants in our research
• Meeting with the ad industry and several charities to ask for their views on our research
• Obtaining children’s TV ad breaks containing charity ads and presenting to Council to give them an impression of the context in which these ads appear
• Collating scheduling data from the last six months of TV ads to demonstrate to Council the kinds of charity ads that have appeared on children’s channels

Although a thorough and comprehensive analysis of our own complaints data - both the nature, and relatively low volume – supports our view that we’re drawing the line in the right place at present, we don’t feel we can ignore the strength of feeling shown by the spontaneous responses in the Harm and Offence research, so we'll be conducting a sense check over the next six months.

As such, we’re now going to be putting more checks and balances in place when assessing complaints about charity and public service ads. Part of this will involve presenting cases to Council and seeking its views at the initial complaints stage. When cases are presented to Council we’ll be providing further contextual information such as the programme content that appeared either side of the ad. This will enable Council to fully consider the nature of the complaint and the context in which the ad appeared.

We’ll review how the complaints and rulings ‘landscape’ looks six months on. Council will then be in a position to determine whether they are satisfied with their position or whether they would like to look at taking a different approach to dealing with complaints about charity and public service ads.

In the meantime, we’ll be communicating these next steps to relevant stakeholders including charity advertisers and trade bodies. We’ll also update them on any outcomes following the review period.

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