Ad description
A TV ad for the travel company Eurocamp, seen on 12 January 2019 included several scenes of people enjoying their holiday, including a toddler in sunglasses lying on their back with their arms behind their head, in bright sunlight on a rubber ring in a swimming pool. The scene was accompanied by a voice-over that stated, “Perhaps you’re a chiller.”
Issue
The complainant challenged whether the ad featured behaviour that could be dangerous for children to emulate and was detrimental to children’s health.
Response
Greenbank Holidays Ltd t/a Eurocamp responded that the film was not intended to reflect or promote sunbathing, but the idea of relaxation on a Eurocamp holiday. It was part of a series and each included the voice-over line, "Perhaps you're a chiller". They said that the child was in a relaxed pose which matched with the voice-over line and would not be interpreted as a child actively sunbathing. They believed that parents would not consider that the child was sunbathing because, as the child was two years old, it was not a realistic action for them to be carrying out. They considered that viewers would interpret the ad as simply showing a child relaxing on a rubber ring, and that this was made clear by the line "Perhaps you're a chiller".
Eurocamp said that they took child safety seriously and considered that the scene complied with NHS guidance on sun safety. They said the scene was very short and it would not be possible to show the measures taken to appropriately protect the child from too much sun exposure, including the amount of time spent in direct sunlight, the use of sunscreen and that the child was outside in an appropriate time of day and time of year. However, consumers would be able to see that the child was wearing sunglasses and clothing.
Clearcast responded that the scene was very brief and they believed it constituted a humorous “slice of life” clip reflecting the enjoyment to be had on a Eurocamp holiday. They did not believe the clip showed a child actively sunbathing and did not think that the child’s skin tone suggested it was sun damaged. Clearcast said that the child was wearing sunglasses and that the closed-in shot did not allow for showing a parent nearby or what safety precautions were taken – for example, wearing sunscreen.
Assessment
Not upheld
The ad included scenes which featured children of various ages enjoying their holidays, playing sport and walking with adults in sunny conditions, as well as the scene about which the ASA received a complaint. That scene featured a young child in sunglasses lying on their back with their arms behind their head, in bright sunlight on a rubber ring in a swimming pool.
NHS Guidance on sun safety stated that children who were exposed to the sun should wear suitable clothing and sunglasses along with sunscreen, and that extra care should be taken to protect very young children because they were particularly at risk of sun damage. Greater care was recommended when children were exposed to more intense sun than experienced in the UK.
The scene featuring the child in a rubber ring was brief and they were wearing sunglasses as recommended by the NHS guidance. Whilst the pose was one which was associated with sunbathing, we did not consider that viewers would interpret the brief scene as showing a child sunbathing, particularly because it featured a very young child who would not normally engage in that activity. We therefore concluded that the ad did not condone a behaviour that was detrimental to children’s health and that it did not breach the Code.
We investigated the ad under BCAP rules
1.2
1.2
Advertisements must be prepared with a sense of responsibility to the audience and to society.
(Social responsibility),
5.2
5.2
Advertisements must not condone, encourage or unreasonably feature behaviour that could be dangerous for children to emulate. Advertisements must not implicitly or explicitly discredit established safety guidelines. Advertisements must not condone, encourage or feature children going off alone or with strangers.
This rule is not intended to prevent advertisements that inform children about dangers or risks associated with potentially harmful behaviour.
and
5.3
5.3
Advertisements must not condone or encourage practices that are detrimental to children's health.
(Children), but did not find it in breach.
Action
No further action necessary.
