Ad description
A poster, seen in October and November 2023, featured an image of the top half of model and influencer Rebecca Louise. She was wearing a shiny red bra top which had several straps and buckles. Alongside the image was the logo of the OnlyFans social media platform and the text “onlyfans.com/rebeccalouise95”. The poster also featured the Instagram logo and the text “@RebeccaLouisex95”.
Issue
Two complainants, who understood that OnlyFans was an internet content subscription service which featured sexual adult content, challenged whether the ad was inappropriate for display in an untargeted medium.
Response
Rebecca Louise said she had developed the ad with careful consideration for potential audiences. She believed it adhered to established advertising guidelines and reflected trends observed in leading brands. She believed that the image used was not suggestive or harmful, and was less provocative than mainstream ads for lingerie or perfume in outdoor media. She pointed out that the ad had appeared for eight weeks, but had attracted only a small number of complaints.
She said the ad deliberately omitted any call to action or explicit information about its subject matter, in order to conceal the nature of the OnlyFans platform from those who might not be aware of it, as well as those who did not wish to engage with it. The OnlyFans logo did appear in mainstream media, where it was associated with high-profile sporting personalities and was not subject to scheduling or targeting restrictions.
The ad was placed with consideration to child safety and not in the vicinity of schools. Ms Louise believed the ad would not appeal to children because it did not feature bright colours, engaging slogans, fun elements or QR codes. She said her audience on social media channels was primarily in the 25-44 age bracket, with 65.6% of all followers falling into that category.
She said the OnlyFans website had stringent restrictions in place to protect those aged under 18. Mobile networks required users to contact their provider and submit identification as proof of age before blocks were lifted. The website also required credit card details and payment authorisation which served as safeguards before any content could be accessed.
Ms Louise understood that ads could be distasteful without causing serious or widespread offence under the Code. The fact that a product was offensive to some people was not grounds for the ASA to determine that the ad breached the Code. She also understood that while not everyone would wish to access adult content, that fact should not prevent it from being advertised, as long as the ads complied with the Code.
Amplify Outdoor, the media owner, said they had not received any complaints directly. They confirmed that the ad was no longer appearing. They said they never intended to cause offence, but simply wished to provide a voice to a legitimate business. They reviewed the image to ensure it was suitable and provided Rebecca Louise with a list of potential sites. Those sites excluded locations within 100 metres of schools. They believed the ad was suitable for public display because it did not mention sexual services or pornographic content. OnlyFans was a locked site that prevented under-18s from accessing explicit content. They believed the image was similar to those used in shampoo, gym wear and lingerie advertising. It was, in their view, relevant to the advertiser’s brand and business and did not employ sexual appeal in a manner that was exploitative of women.
Amplify pointed out that the poster’s use of an image and social media icons was consistent with many other poster ad campaigns. They did not believe that all those who saw the poster would view it as being sexual in nature. Children in general did not know about OnlyFans and adults did not need to explain the content to them. Amplify drew a parallel with alcohol and gambling ads that were similarly displayed in outdoor media. They added that the OnlyFans logo appeared widely at boxing matches, golf tournaments and other sporting events, and pointed out that OnlyFans included content other than that of a sexual nature - for example, Rebecca Louise had subscribers to her workout page.
Assessment
Upheld
The ad featured an image of Rebecca Louise alongside the web address of her OnlyFans page and the address of her Instagram page. The ad therefore promoted Rebecca Louise and her business on those online platforms. The ASA understood that the OnlyFans platform contained various kinds of content posted by subscribers to its service, including adult sexual content. We acknowledged that some people would find ads for such services distasteful because of the nature of the service advertised, particularly if they appeared in an untargeted medium. However, the Code stated that the fact that a product was offensive to some people was not grounds for finding a marketing communication in breach of the Code. Legitimate businesses were permitted to advertise as long as they did so responsibly. Our assessment was, therefore, focused on a consideration of the specific ad itself: the image; the text; and the overall impression and placement of the ad.
The image showed Ms Louise wearing a push-up bra. The bra was made of shiny red material and featured buckles. It had additional straps that outlined the shape of her breasts and drew attention to her cleavage. Her head was at a slight angle, her mouth was slightly open and her eyes were looking directly into the camera. One hand was raised, which suggested that she was interacting with viewers. We considered that her expression, in combination with the styling and her pose, was suggestive and coquettish. We considered that the styling, pose and expression would be seen as sexualised and provocative. Although we acknowledged that it formed her social media handle, we considered that impression was further reinforced by the accompanying text RebeccaLouisex95, which included the word “sex”.
We acknowledged that the image of Ms Louise was relevant to the OnlyFans service and in keeping with some of its usual content, which was sexual and explicit, but that the image was not exploitative or degrading in tone. Notwithstanding that, we considered that the combination of the image, the OnlyFans web address and the handle “@RebeccaLouisex95” meant that the ad taken as a whole would be seen as overtly sexual, particularly to those who were familiar with the content of the OnlyFans platform.
The ad was shown on a poster in London close to a main road, which was an untargeted medium, and was therefore likely to be seen by large numbers of people, including under-18s. We acknowledged that Amplify had applied a targeting restriction in selecting a site that was not within 100 metres of any schools. We considered, however, because the ad was overtly sexual and was displayed in an untargeted medium where it had the potential to be seen by a large number of people, including children, it was irresponsible and likely to cause widespread offence. We concluded that the ad breached the Code.
The ad breached CAP Code (Edition 12) rules 1.3 (Responsible advertising) and 4.1 (Harm and offence).
Action
The ad must not appear again in its current form. We told Rebecca Louise to ensure that future advertising in outdoor media was not overtly sexual and to avoid causing widespread offence.
