Ad description
A radio ad broadcast on 25 November 2015 for the Guide Dogs for the Blind Association featured a little girl visiting Father Christmas in his grotto. When asked what she would like for Christmas, the little girl asked for a puppy because she had been really good but her mother had told her that they did not have time to look after one. Father Christmas replied, "How about a special Guide dog puppy like Snowy? Your Mummy can sponsor one like her for just £1 a week. You'll get photos, pupdates [sic] and a cuddly toy, then one day when Snowy's all grown up, she'll change a blind or partially sighted person's life forever!" He continued, "If you want to sponsor a guide dog puppy for someone special this Christmas, text SANTA to [telephone number] or visit [website address] ... and tell them Santa sent you."
Issue
A listener challenged whether the ad breached the Code because it was likely to be of particular interest to children and encouraged them to ask their parents to make a purchase on their behalf.
Response
The Guide Dogs for the Blind Association (GDBA) said they did not accept puppy sponsorships from under-18s. They designed their appeals to target adults only and did not consider that an ad featuring Santa and a young child encouraged children to ask their parents to sponsor a puppy. Rather, the ad was aimed at adult listeners and at encouraging parents to consider sponsoring a puppy as a Christmas gift for their loved ones.
GDBA said the ad was targeted towards women aged 35 and over, which they believed was demonstrated in the voice-over, "Your mummy can sponsor a puppy" and "If you want to sponsor a guide dog puppy for someone special this Christmas", i.e. for the mother referenced in the ad to sponsor a puppy for the child featured. They also said the campaign ran from 23 November until 6 December in order to avoid the school holidays.
Radiocentre felt that, whilst the ad included “Santa” and a child voice-over, listeners would understand that the message of the ad was about adult sponsorship only of a guide dog puppy via the reference “Your mummy can sponsor a puppy”. They noted the scenario between “Santa” and a child, but felt that it was equally appealing to an adult (as the only acceptable potential sponsor) as to a child and, therefore, did not feel the message of puppy sponsorship was addressed specifically to children. They took the reference “If you want to sponsor a puppy for someone special” as one meaning the mother wanting to sponsor the puppy for her child, not the other way round.
Assessment
Upheld
The ASA acknowledged the complainant’s concern that the ad’s setting targeted children and GBDA’s comments that their appeals were targeted to adults and adults aged over 18 because only they were eligible to take out a puppy sponsorship. However, BCAP Code rule
16.3.4
16.3.4
address fund-raising messages to children or likely to be of particular interest to them.
stated “Advertisements seeking donations for … a charitable body must not address fund-raising messages to children or [be] likely to be of particular interest to them”.
We acknowledged the ad ceased to be broadcast in the three weeks before Christmas and therefore, had been kept away from the school Christmas holiday period. Nevertheless, we considered its Christmas Grotto setting was still relevant to the time period during which it was broadcast, given that it would not be unusual for festive ads to be broadcast in early December. Additionally, we considered that the use of such settings was common in ads for a variety of products during the festive period, rather than just those aimed exclusively at children.
Although the ad was not broadcast during the school holidays, it still featured a child visiting Father Christmas' grotto, explaining what they would like for Christmas and why they could not have it. Father Christmas suggested that there was a way to have a special puppy instead, and that the benefits that came with 'owning' it were that the child would receive photos of the puppy as well as a cuddly toy. We considered that those were all elements of the ad’s content that were likely to be of particular interest to children.
We acknowledged the ad stated that the child's mother would need to sponsor the puppy and puppy sponsorship was suggested as a Christmas gift more generally. However, we considered the ad addressed the adults and parents who might be listening to explain how they could find out more information about puppy sponsorship only at the end of ad. The majority of the ad's dialogue took place between the child and Father Christmas, explaining that the child’s mother could buy a puppy sponsorship so that the child could still 'receive' a dog for Christmas and the benefits that came with that. For the reasons given above, we concluded the ad was also addressed to children.
In addition, BCAP Code rule 5.9 5.9 Advertisements must not include a direct exhortation to children to buy or hire a product or service or to persuade their parents, guardians or other persons to buy or hire a product or service for them. prohibited ads from directly exhorting children to buy a product. We considered the question “What do you want for Christmas?” triggered a discussion about a very specific gift and the ad gave an explicit statement, through the claim “Your Mummy can sponsor ...”, which we considered children were likely to understand to mean that if they wanted a guide dog puppy, they could ask their parents for one. However, because the ad had made clear that only adults/parents could buy a sponsorship, we considered that particular statement did not go so far as to amount to a direct exhortation to children. We therefore concluded the ad did not breach the Code in that regard.
The ad breached BCAP Code rule
16.3.4
16.3.4
address fund-raising messages to children or likely to be of particular interest to them.
(Charities). We also investigated the ad under BCAP Code rule
5.9
5.9
Advertisements must not include a direct exhortation to children to buy or hire a product or service or to persuade their parents, guardians or other persons to buy or hire a product or service for them.
(Children) but did not find it in breach.
Action
The ad must not be broadcast again in its current form. We told the Guide Dogs for the Blind Association to take care when featuring elements which were likely to be of particular interest to children in future festive advertising and to ensure that their fund-raising messages were not addressed to them.
