Ad description
A listing on www.cv-library.co.uk, a job vacancy website, for the company IT Career Change Ltd, seen on 3 September 2024, featured a heading which stated, “Trainee Health & Safety Advisor”. Text underneath stated, “Are you looking to kick-start a new career in health & safety? We are recruiting for companies who are looking to employ our Health & Safety Traineeship graduates to keep up their growth. The best part is you will not need any previous experience as full training will be provided. You will also have the reassurance of a job guarantee within 20 miles of your location upon completion […]”. Further text explained how the programme worked including information about the different training modules and being placed into a job upon completion. Text at the bottom of the listing stated, “Please note that this is a training course and fees apply”.
Issue
The complainant challenged whether the ad was misleading because it did not make sufficiently clear that it was for a training course and career placement programme rather than a genuine trainee job role.
Response
IT Career Change Ltd said that since 2019, their ads had had over 750,000 views and they had received over 30,000 applications as a result. To their knowledge there had only been two people who had complained that their ads were misleading, which equated to 0.0002% of people who had viewed them. Based on those figures, they did not believe the ad was misleading.
They pointed out that in the copy of the ad, text stated, “The traineeship is completed in 4 easy steps, you can be placed into your first role in as little as 3-6 months” and then listed all the training applicants would need to have completed before being placed into the role.
The ad then referred to the cost of the training where it stated, “At a one off cost of £1095, or a deposit of £162 followed by 10 interest free monthly instalments of £113, this represents a great opportunity to start a rewarding career in health & safety and have a real career ladder to start climbing. If you are not offered a role at the end of the training we will refund 100% of your course fees”. Applicants were therefore made fully aware that a cost was involved to fund their training before they would be placed into a role.
They said that was reinforced by text at the bottom of the ad, directly above the ‘apply’ button, which stated, “Please note that this is a training course and fees apply”.
They said their ads also included filter questions that had to be ticked before someone could submit an application, which made sure they had understood that it was a training package that upon completion would lead onto a job role and also made them fully aware that the training was self-funded. Applicants were required to tick a box on two separate questions to say they understood. They therefore believed it was impossible for someone to be unaware of the training element before applying.
They further explained that they did not want applications from people who had not understood what was involved, as it wasted their consultants’ time in trying to contact them; they made it as clear as possible in the ad what was involved so as to avoid that.
Assessment
Upheld
The ASA understood that the listing appeared on a job vacancy website and therefore consumers visiting that site would be searching for employment opportunities. We also understood that users of the website would usually access the ad via searches or other job lists which would include the job title and a short extract from the start of the listing. Given that, it was important that any initial information made it clear that they were clicking through to view a training course rather than a job vacancy.
We considered that the heading of the ad which stated, “Trainee Health & Safety Advisor” and the text immediately underneath that stated, “Are you looking to kick-start a new career in health & safety? We are recruiting for companies who are looking to employ our Health & Safety Traineeship graduates to keep up their growth. The best part is you will not need any previous experience as full training will be provided” were likely to be understood by consumers to mean the ad was for a trainee health & safety role and that candidates who had little or no experience in that sector were welcome to apply for the role, plus full training would be provided on the job. We understood that users of the website would see that initial text first before clicking into the full listing.
Whilst we acknowledged that further text in the body of the ad explained that IT Career Change were promoting a training course and career placement programme and that fees applied, we considered that it was not sufficient to counter the strong impression given by the heading “Trainee Health & Safety Advisor” and the accompanying text at the top of the ad stating “Are you looking to kick-start a new career in health & safety? We are recruiting for companies who are looking to employ our Health & Safety Traineeship graduates to keep up their growth. The best part is you will not need any previous experience as full training will be provided” that the ad was for a genuine employment vacancy. We considered that the text in the body of the ad contradicted rather than qualified the headline and accompanying initial text. Also, we noted that this text would not have been visible in the search result and would only have become visible by clicking into the full listing.
For those reasons, we considered that the ad did not make sufficiently clear that it was for a training course and career placement programme which consumers had to pay for, rather than a paid employment role with training on the job. We therefore concluded that the ad was misleading.
The ad breached CAP Code (Edition 12) rules 3.1 and 3.3 (Misleading advertising), 3.9 (Qualification) and 20.2 (Employment).
Action
The ad must not appear again in the form complained of. We told IT Career Change Ltd to ensure their ads did not misleadingly imply they were offering genuine job vacancies if they were offering paid-for training courses and career placement programmes. This should be reflected in the initial job listing that users of the website would view in a search result and in the headline of the ad as well as the body text.
