Background
These ads were identified for investigation following intelligence gathered by our Active Ad Monitoring system, which uses AI to proactively search for online ads that might break the rules.
Ad description
A paid-for Meta ad and display ad for Ocean Finance credit card, seen on 27 November 2024:
a. The paid-for Meta ad featured an image of an Ocean credit card with the text, “IT’S BLACK FRIDAY”. “BLACK” was crossed out and replaced with “just”. Further text stated, “Up to £8,000 credit limit”, “Spend savvy” and “Borrow and spend responsibly”. The caption stated, “Check your eligibility for our credit cards. Up to £8,000 credit limit. Get an answer in 60 seconds. Checking won’t affect your credit score”.
b. The display ad also featured the text, “IT’S BLACK FRIDAY”. “BLACK” was crossed out and replaced with “just”. Further text stated, “Credit Limit up to £8,000. Ocean. Check your eligibility in 60 seconds for our Credit Cards. No impact on your Credit Score ”.
Issue
The ASA challenged whether the ads were irresponsible because they encouraged consumers to spend regularly on non-essential purchases on a credit card.Response
Intelligent Lending Ltd said the ads were designed to discourage irresponsible spending and to prompt consumers to give consideration before spending.
The word “BLACK” was replaced with “just” and was designed to appear as a handwritten correction to reinforce the message that Black Friday should be treated as any other day. They said, “Just Friday” was meant to reduce the perceived need to rush into purchases or treat it as an extraordinary event. The capitalisation of “BLACK” and removal of capitalisation in “just” was intended to be a reminder that while consumers may indeed use credit, this should be done with caution, as it was just another day and not a special occasion.
Additionally, the ads included the messages “Borrow and spend responsibly” and “Spend savvy”, which emphasised the importance of informed decision-making when it came to spending, both during Black Friday and at any other time, and reinforced their commitment to promoting responsible financial behaviour. The messages highlighted the importance of thoughtful spending and encouraged consumers to avoid impulsively purchasing non-essential items during the limited time event.
Along with “Just Friday”, these messages were intended to reduce ‘hype’, and caution against impulsive purchasing. Given that, they did not consider that the messaging in the ads encouraged regular or unnecessary spending on a credit card.
They said the credit limit and eligibility check information mentioned in the ads was intended to convey factual details about the product and service. The nature of the product being a credit-building card was considered in all their promotions and further reinforced their message in the campaign to discourage unnecessary spending.
Assessment
Upheld
The CAP Code required marketers to ensure advertising was prepared with a sense of responsibility to consumers and to society.The ASA noted Intelligent Lending’s comment that the addition of “just” with “BLACK” crossed out was intended as a message that Black Friday should be treated as any other day. We also noted that “Just Friday” was intended to reduce the perceived need to rush into purchases or to treat Black Friday as an extraordinary event. However, we considered the reference to Black Friday, which was in capital letters, put emphasis on using a credit product for the event, which typically offered savings on predominantly non-essential products such as technology, beauty and clothing. In addition, we considered the addition of “just”, to read “it’s just Friday”, was likely to be understood to mean that consumers should regularly spend money on a credit card ‘just because’ it was a Friday. As such, we considered the reference to regularly spending in such a way on a Friday, a day sometimes seen as a time for reward after the working week, was likely to be understood as encouraging consumers to apply for the credit card just to treat themselves.
We acknowledged Intelligent Lending’s comment that the statements “Borrow and spend responsibly” in both ads, and “Spend savvy” in ad (a), were intended to reinforce their commitment to promoting responsible financial behaviour and not overspending and were meant to encourage consumers to avoid impulsively purchasing non-essential items. However, we considered those statements were not sufficient to counteract the main message in the ads.
Because we considered the ads encouraged consumers to spend regularly on non-essential purchases using a credit card, we concluded they were irresponsible.
The ads breached CAP Code (Edition 12) rule 1.3 (Social responsibility).
Action
The ads must not appear again in the form complained of. We told Intelligent Lending Ltd to ensure that future ads did not irresponsibly encourage consumers to spend regularly on non-essential purchases using a credit card.
