Ad description
A radio ad for the film “Lights Out”, broadcast on 16 August at 7:25 pm on Capital Radio East Midlands, featured an introductory voice-over stating, “From the visionary filmmaker behind the Conjuring”. A child’s voice then said, “Every time I turn the lights off, there’s this woman.” A woman said “I’ve been seeing her too”, followed by a scream. The voice-over continued, “Critics are calling it one of the year’s best horrors.” The woman then said, “Everyone is afraid of the dark, and that’s what she feeds on.” There was the sound of more screaming. The voice-over said, “Chilling.” The woman said, “We need to leave.” The voice-over continued, “It will leave you sleeping with the lights on.” The child said, “She won’t let that happen.” The woman, sounding very distressed, shouted, “Stay in the light!”, followed by sinister noises. The voice-over said, “Lights Out. In cinemas Friday. Certificate 15.”
Issue
The complainant challenged whether the ad had been scheduled appropriately, because it had frightened her child.
Response
This is Global Ltd confirmed that the ad the complainant heard was broadcast at 7:25 pm. They said that, due to the nature of the film and the restriction imposed by Radiocentre, they had only aired the ad between 7 pm and 6 am in time slots with a low percentage of listeners under the age of 16. RAJAR (Radio Joint Audience Research) figures showed that the proportion of children aged under 16 listening at 7:25 pm was 7%.
Warner Bros said that they regretted that a child had been frightened by the ad. However, they said that the ad had been edited to ensure that it was appropriate for broadcast within radio programming aimed at the film’s target audience, which was individuals aged 15 years and over. They said that the ad featured unsettling and mildly scary audio clips from the film rather than anything overtly scary or distressing.
They said the ad had been pre-vetted by Radiocentre, who advised that the ad should not be broadcast at times when those under-16 were likely to be listening (e.g. breakfast, drive-time, school-run times and school holidays). Warner Bros said they had taken steps to ensure that broadcasters were made aware of the restrictions imposed by Radiocentre. They also made broadcasters aware of RAJAR figures detailing the child audience in the relevant time slot and requested that the ad was broadcast around programming aimed at the ad’s target audience.
Radiocentre noted that its scheduling advice had been followed and had nothing to add to the broadcaster and advertiser responses.
Assessment
Not upheld
The ASA noted that, in line with the plot of the film, the audio clips in the ad suggested that there was something threatening associated with being in the dark or having the lights off. We acknowledged that a fear of the dark was common among young children. We agreed with Radiocentre that the ominous tone of the ad meant that it should have been scheduled away from times when children aged under 16 were likely to be listening in order to minimise the possibility of children hearing it.
Prior to scheduling the ad, This is Global had consulted RAJAR figures for the time that the ad was to be aired and those figures had shown that the under-16 segment typically comprised a low proportion of the audience at that time. The ad had been heard during school holidays, when children’s listening patterns might be expected to differ slightly compared to term time. However, we noted that RAJAR figures for the specific day and time that the ad was broadcast showed that only 7% of the listening audience was under 16, which we considered minimal. We concluded that the scheduling advice given by Radiocentre was appropriate and that it had been applied responsibly by the broadcasters, and that the ad therefore did not breach the Code.
We investigated the ad under BCAP Code rules
5.1
5.1
Advertisements that are suitable for older children but could distress younger children must be sensitively scheduled (see Section 32: Scheduling).
(Children),
32.1
32.1
Broadcasters must exercise responsible judgement on the scheduling of advertisements and operate internal systems capable of identifying and avoiding unsuitable juxtapositions between advertising material and programmes, especially those that could distress or offend viewers or listeners.
and
32.3
32.3
Relevant timing restrictions must be applied to advertisements that, through their content, might harm or distress children of particular ages or that are otherwise unsuitable for them.
(Scheduling), but did not find it in breach.
Action
No further action required.
