Ad description

An ad for the videogame 'Call of Duty Modern Warfare III', seen on the PlayStation Store on 15 February 2024, featured an image of a soldier in a skull mask holding a gun.

Issue

The complainant, whose child saw the ad on their PlayStation account, challenged whether it had been irresponsibly targeted.

Response

Sony Interactive Entertainment Network Europe Ltd t/a PlayStation said adults represented the majority of console users, and they offered a variety of settings that allowed parents and guardians to make decisions about what their children could view on the PlayStation Store and Network. PlayStation consoles required that at least one adult user (18+) registered an account on the PlayStation Network (PSN) and children could not hold a full PSN account. The PSN was a service which allowed users to buy digital format games for PlayStation consoles via the PlayStation Store, PlayStation’s direct-to-consumer storefront.

The PlayStation Store was not automatically shown to users unless they scrolled to it on a PlayStation console, and was only visible if it was selected by the user. The default was for the system to load the most recently played game when the console was turned on. In their view, a child user’s ability to see limited details about a game title, such as the game’s name, on the PlayStation Store’s landing page, was similar to the experience of shopping for videogames in a physical retail shop or an online eCommerce website.

PlayStation said if a user aged 7 to 17 years old wanted to play on a PlayStation console, their responsible adult could set up a child account and apply parental controls settings, such as only allowing access to game content they considered age appropriate. Titles that appeared in the PlayStation Store were not addressed to or targeted directly at children. The Call of Duty Modern Warfare III background would display if the user highlighted the Call of Duty tile at the bottom of the page, and it was not possible to separate that landing page from the PlayStation Store. Some game titles appeared for a general audience, while others were based on previous purchases.

No game content was available to view, purchase or download from the landing page. The images on that page that referenced a specific game took the user to the product listing, called the “game hub”. If a child user tried to proceed to the game hub page for a title above their registered age, the parental controls settings applied by the adult user meant that the child user would see an “age restriction” warning and would not be able to proceed further.

Assessment

Not upheld

The ad was for Call of Duty Modern Warfare III, an 18-rated videogame and was seen on the PlayStation homepage, which the ASA understood displayed the PlayStation Store as an option for all users who visited it. If a user navigated to the PlayStation Store icon within the homepage, they might see the ad without selecting a particular game title. They would also see it if they hovered over the Call of Duty Modern Warfare III icon. The ad was therefore seen in untargeted media, in this case by a child logged into a child’s PlayStation account.

We considered that the content of the ad was not especially graphic and, while the character was holding a gun, we noted it also did not include images of violence. As such, we considered that it was not unsuitable for an untargeted medium. In addition, we understood that an adult user could set up a PlayStation child’s account on the console and use the parental controls to restrict their access to certain videogames and media. That meant a child using the PlayStation Store with those restrictions in place would not be able to advance any further than the landing page to view, purchase or download the 18-rated content. For those reasons, we concluded that the ad had not been irresponsibly targeted and therefore did not breach the Code.

We investigated the ad under CAP Code (Edition 12) rule 1.3 (Social responsibility), but did not find it in breach.

Action

No further action necessary.

CAP Code (Edition 12)

1.3    


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