Ad description
An ad for Coral, seen on a mobile digital billboard on 13 March 2024. The ad featured a man dressed in the style of an attendee of a horse racing event, looking through a pair of binoculars. On-screen text around the man stated “THE HEAD TO TOE TWEEDERS […] WE’RE HERE FOR IT […] CORAL”. The digital billboard was mounted on a parked van which was seen, alongside several other such vehicles, in Cheltenham during the Cheltenham Festival horse racing meeting.
Issue
The complainant challenged whether the ads had been responsibly placed, because the van had been parked close to two schools.
Response
Coral said that every year during the Cheltenham Festival they deployed eight mobile digital billboards (digivans) on each day of the festival. The digivans focused largely on the primary route between the racecourse and the town centre. They understood that road was the main arterial route to the event for motorways, A-roads and the train station. Coral said they had followed the ASA’s recommendation that ads in outdoor media which promoted age-restricted products were not placed within 100 metres of a school. As well as adhering to that recommendation, Coral said the digivans had been instructed to stay, where possible, at least 200 metres away from any school. They accepted, however, that the mobile format of the ads, combined with issues such as potentially limited parking spaces, meant that the digivans could sometimes be within 200 metres of a school. Coral provided a map showing the Digivans’ locations, relative to the local schools.
During the festival the digivans were instructed to park facing the direction of travel of people making their way to the racecourse in the mornings. During racing, the digivans drove around the town centre and near the entrance to the racecourse. After racing had concluded, they again parked facing the direction of travel of people making their way to the town centre or station from the racecourse. The digivans were scheduled to be live from 9am to 5pm. Coral said that, although the digivans might arrive before 9am to secure a suitable location, drivers were instructed not to turn on their screens until 9am. They said the screens would therefore only have been activated after 9am when, children would have already entered the school grounds. After racing finished the digivans were moved to approach oncoming traffic back into the town centre or station, nearer to the racecourse and further away from schools.
After being made aware of the complaint Coral said they had re-briefed their media partners and agencies to ensure that any similar future campaigns abided to their 200-metre guidance wherever possible, despite not having been parked within 100 metres of a school in the instance complained about. Mobile Media Group said they took care to ensure that any campaigns for age-restricted products that they published were not targeted at children, and provided in-house guidance to employees on such matters. They also said that the digivans had been parked over 100 metres from, and not in direct line of sight of, a local primary school, with their screens facing passing traffic. They said the digivans were intended to be seen by people on their way to the racecourse. They confirmed that they received no complaints directly in relation to the campaign.
Assessment
Not upheld
The CAP Code required that marketing communications for gambling must not be directed at those aged younger than 18 years through the selection of media or context in which they appeared, and that no medium should be used to advertise gambling if more than 25% of its audience was under the age of 18. The ads were displayed on mobile digivans parked in various locations in Cheltenham during the four-day race meeting festival, between Tuesday and Friday. In the mornings, the digivans were parked next to the main route between the town centre and the racecourse.
We assessed the locations of the digivans provided by Coral, which correlated with the location provided in the complaint. We acknowledged that the digivans had taken up various locations throughout the day and that they were, by their nature, displayed in an untargeted medium where the ads were likely to be seen by large numbers of people, potentially including under-18s. However, the morning locations taken up by the digivans were over 800 metres (a ten-minute walk) from a secondary school, and approximately a 150-metre walk from a primary school. Furthermore, we noted that there was no direct line of sight from the primary school grounds to the digivan’s locations. In addition, the drivers had been instructed, where possible, to remain 200 metres away from such locations and to activate their screens after 9am, once the school day had started. We considered that instruction would further reduce the number of under-18s who would have likely seen the ad. While we acknowledged that children may have seen the ad, we considered it unlikely that people under 18 comprised more than 25% of the audience. Because the digivans had not been parked within 100 metres of a school and with no direct line of sight, and because the displays were only activated after 9am, and remained 200 metres away from sensitive locations where possible, we considered that appropriate steps had been taken to comply with the relevant media placement restrictions.
We therefore concluded the placement of the digivans, and the subsequent display of their ads, did not breach the Code. We investigated the ad under CAP Code (Edition 12) rules 1.3 (Compliance), 16.1, 16.3 and 16.3.13 (Gambling), but did not find it in breach.
Action
No further action required.
