Background
Summary of Council decision:
Three issues were investigated, all of which were Not upheld.
Ad description
Two TV ads and two video on demand (VOD) ads promoted Unilever’s brand, Dove and their Self-Esteem Project, seen in June and July 2023:
a. The first TV ad began with text that stated “Sensitive Content. The following film features real stories about body appearance that may be upsetting to some viewers”. A home video of a young child reading was then shown before the ad cut to a screen that stated “Mary’s story”. Photos and home videos of Mary from childhood through to adolescence were shown, while a woman sang You Are So Beautiful. They included: home videos of Mary’s birthdays, the last of which showed her unwrapping a smartphone and then using it, followed by various full body photos Mary had taken of herself in side profile, holding her arm over her stomach; A social media video post of a woman wearing a waist cincher who stated, “If you want a small waist this summer, well your favourite product is here” along with social media photos of women with exposed flat stomachs which were shown being ‘liked’; further content from social media, including a video of a woman measuring her thigh with a tape measure while saying, “Get yourself a tape measure, thigh gaps are in”; recordings Mary had made of herself measuring her wrist with her finger and thumb and pinching the side of her waist, weighing herself on a set of scales, and portrait photos she had taken of herself in the mirror, followed by a photo of handwritten text that stated “look at yourself your gross ugly self”; and journal entries that included “today I overate at lunch”. That was followed by videos of Mary in an Eating Disorder Unit with a hospital wristband and an intravenous drip, and a screen with the Dove logo and text that stated “The cost of toxic beauty content is greater than we think”. An older, but still youthful Mary was then shown and on-screen text stated “Mary In recovery from an eating disorder”.
Young women were then shown sitting and hugging a guardian while on-screen text stated their names and a mental health condition they were recovering from, including depression, self-harm, eating disorders, anxiety and body dysmorphia. On-screen text stated “Social media is harming the mental health of 1 in 2 Kids. Join us to protect their mental health. 2023 Dove Self-Esteem Project Research for Kids Mental Health”.
b. The second TV ad was a shorter version of ad (a). The ad started with on-screen text that stated “Social media is harming the mental health of 1 in 2 kids” and smaller text at the bottom of the screen stated “CW: Eating Disorder” and “2023 Dove Self-Esteem Project Research for Kids Mental Health”. That was followed by similar home video footage to ad (a). Then video footage of Mary in the Eating Disorder Unit was shown and was captioned “Mary In treatment at 14”. On-screen text then stated “Join us to protect kids' mental health Search Dove Self-Esteem Project”. A clip of Mary was then shown and was captioned “Mary. In recovery at 19”.
c. The first VOD ad was the same as ad (a).
d. The second VOD ad was the same as ad (b).
Issue
The ASA received 136 complaints:
1. The complainants challenged whether the ads were irresponsible and distressing, in particular to those affected by insecurities about their body image or those affected by an eating disorder;
2. 26 complainants challenged whether the ads were appropriate for children to see; and
3. 10 complainants challenged whether ads (a) and (d) were appropriate to be shown during Love Island on ITV2 and the VOD service ITVX.
Response
1. Unilever UK Ltd said they had a 20-year history in working to highlight issues that impacted self-esteem. Their latest campaign, which included the ads under investigation, aimed to raise awareness of the impact social media could have on mental health conditions such as eating disorders, depression and anxiety. They were sensitive topics, and people did not necessarily know what avenues of support were available. They intended the ads to alert parents and young adults to the existence and potential consequences of that type of social media content, and to make people aware of where they could find support. Their research had shown that nine in ten young people were exposed to “toxic” beauty content on social media; eight in ten youth mental health specialists considered that exposure to harmful beauty content on social media could lead to physical consequences like disordered eating or self-harm; and 51% of young people aged 14 to 17 had seen content that encouraged restricted or disordered eating behaviours.
Unilever had consulted with a range of experts during the production of the ads to avoid presenting eating disorders in an irresponsible manner. In preparing the ads for broadcast in the UK, they consulted the Centre for Appearance Research, and past users of the Maudsley Hospital and King’s College London’s eating disorder support services to ensure they were comfortable with the ads. Similar consultations had taken place in the ads’ US development. Those consultations were to ensure Unilever understood what scenes to include and which to omit from the ads in order to tell Mary’s story in a respectful and ultimately positive manner. The experts and charities were conscious that the ads may trigger audiences and had made various recommendations to limit that risk while still retaining the ads’ core message. One of their recommendations was to include a content warning at the beginning of each ad. Additionally, Unilever had consulted with Clearcast to ensure the warning was shown for an appropriate amount of time. Unilever said that after they had been informed of the ASA’s investigation they reviewed the visibility of the content warning on ad (b) and increased its size to make it clearer.
Unilever had conducted focus group screenings of the ads in the UK. From that feedback, along with the work they had done with various charities and experts, they were satisfied the ads had addressed the subject in a sensitive manner. They said leading eating disorder healthcare providers supported the ads and provided positive feedback.
In Unilever’s view, the campaign landed on the right side of the line in its depiction of a difficult issue, and the overall effect of the ads was a positive one. The ads had drawn attention to negative body images on social media, such as having a “thigh gap” or a “cinched” waist, and connected those images to Mary’s story to show the impact they were having. In doing so, Unilever said they highlighted the harmful content young people were exposed to on social media and its consequences without glamorising it or embarrassing those who suffer from an eating disorder.
Clearcast had held extensive discussions with Unilever about the ads and were alive to the fact some of the imagery used could be triggering and distressing. They were happy for a content warning to be included, but their primary consideration was whether the content itself, regardless of the warning, was justifiable. Clearcast ultimately decided the ads presented an important and helpful message that drew viewers’ attention to the support available, and that recovery from these conditions was possible.
Clearcast understood Unilever had consulted with various experts in relation to self-esteem, body image, mental health and eating disorders throughout the clearance process. That included seeking advice on the language used. Additionally, they understood, to ensure their safety and wellbeing, Unilever had chosen to feature only young people who felt able to speak about their journey from a strong place of recovery.
ITV said in their view, ads (b) and (d) contained messaging that was emphatic, socially responsible, powerful and empowering. They referred to two online news articles which stated that the number of young people and children treated for eating disorders had more than doubled since 2017.
Sky said ad (d) was shown on their VOD service, NOW. They understood the ad had been reviewed by Clearcast and they added their own restrictions on when the ad could be shown, in an effort to avoid any thematic clashes arising between the ad’s subject and the surrounding content.
2. Unilever said the target audience for the ads was “Housepersons with Children” – a term defined by the Broadcasters Audience Research Board (BARB) as houseperson living in a household in which a child, or children, aged 0 to 15 also lives – and that according to a third-party media research and planning software company the group included people aged between 21 and 77, of whom 94% were aged between 24 and 55. They said all purchased advertising had aligned with Unilever’s media guidelines of not targeting children.
Unilever purchased 10,500 ad spots across linear TV for the campaign. They requested that ads (a) and (b) should not be shown before 9pm and 6pm, respectively. Additionally, they had requested the ads not be shown around programming that was popular with children. They manually reviewed all spots with their media agency to remove any that might have been inappropriate due to the themes of the surrounding programming. That included children’s or family programmes, or programming focused on food, eating or body image. During the first 10 days of the campaign, 0.5% of the ads were shown earlier than intended, and Unilever said they urgently raised that matter with the relevant channels to prevent it happening again.
Clearcast decided against imposing a timing restriction on the ads as doing so would have limited the ads’ ability to raise awareness of the avenues of support featured.
3. Unilever said although Love Island was targeted at young adults it was not targeted at children, and that its content and themes were not appropriate for children. That was reflected in it being broadcast after the 9pm watershed. They said ITV were shown the ads before broadcast and were satisfied with them provided that they were not shown around content that could contradict their message. ITV directed the ads away from ads for skincare products, fast food, slimming products, cosmetics, social media service, and mobile phone manufacturers.In relation to ITV’s VOD service ITVX, Unilever said their audience targeting included the Housepersons with Children category, Love Island and programme select targeting. They said viewers had to be aged over 18 years of age to be eligible for an ITVX account, and highlighted that only ad (d) had been shown on ITVX.
Unilever said Love Island had played a central part in recent debates around online harms and body image. They referred to a 2019 YouGov study that found physical appearance was much more important to Love Island viewers than the public at large. They said the ads were targeted specifically during Love Island to draw attention to those issues and to alert those in need that help was available.
ITV said ad (a) was broadcast during Love Island on 3 July on ITV2. Ad (d) was broadcast during the same programme on ITVX. They said Love Island was precisely the programme which those ads should be scheduled around, as they could act as a warning to Love Island’s audience of the harm that could arise from unmonitored and inappropriate social media use. ITV acknowledged there were parts of the ads that were emotive, but felt they were also powerful and empowering, and that the outcome shown in the ads was positive.
Assessment
1. Not upheld
The CAP and BCAP Codes stated that marketing communications must be prepared with a sense of responsibility to their audience and society. Additionally, they stated marketing communications must not cause fear or distress without justifiable reason. The CAP Code also stated that if it could be justified, the fear or distress should not be excessive.
The ads had all started with a content warning and showed clips of a real life individual, Mary, engaging in behaviour associated with eating disorders, and watching social media content that glamorised a thin body type. The ads included imagery such as a waist being pinched, the circumference of limbs being measured, Mary weighing herself, and scenes from inside an eating disorder treatment unit. Ads (a) and (c) also referred to body dysmorphia, depression, self-harm, and anxiety. The ASA considered the imagery and language used was emotive. It was likely to resonate strongly with those who had, or had recovered from, an eating disorder or the other conditions mentioned. Additionally, the ads could cause a significant emotional impact with a wider audience.
We understood the intention of the ads was to raise awareness of the potential harm social media could cause to young people by promoting unhealthy and unrealistic body ideals, partly through showing recreated content that could encourage behaviours associated with eating disorders. The ads concluded by showing Mary and other young women in recovery, to highlight that support was available and recovery was possible. Ads (a) and (c) also included information about organisations that could help with the featured conditions.
However, the ads contained imagery that could resonate with behaviours associated with eating disorders, particularly in relation to viewers who had, or were recovering from, an eating disorder, and that the imagery could be distressing for viewers generally. We understood that Unilever, for that reason, following consultations with various experts, had included a content warning at the beginning of the ads.
The ads presented lines of support for those affected by social media content and its relationship to the conditions shown, and ads (a) and (c) featured references to and contact information for two different charities that offered support for those issues. All of the ads began with a content warning. We did not consider that the inclusion of the information about charities or the content warnings would necessarily remove the potential for the ads to cause distress or to encourage harmful behaviours.
The overall message of the ads was to raise awareness of the impact social media could have and that there was support available to give hope that recovery was possible for those affected by eating disorders or insecurities around their body image. We considered the ads were unlikely to encourage or be understood as condoning harmful behaviour. Furthermore, while we acknowledged the subject matter could be difficult for members of the wider public to watch, we considered the context of the overall message, as raising awareness and promoting support, was likely to be understood.
We therefore concluded the ads were not irresponsible and did not cause unjustifiable distress.
On that point, we investigated ads (a) and (b) under BCAP Code rules 1.2 (Social responsibility), 4.1, and 4.10 (Harm and offence), but did not find them in breach.
On that point, we investigated ads (c) and (d) under CAP Code (Edition 12) rules 1.3 (Social responsibility), and 4.2 (Harm and offence), but did not find them in breach.
2. Not upheld
We understood Clearcast had not applied a timing restriction to ads (a) and (b). However, we understood Unilever had requested that ad (a) not be broadcast before 9pm, and ad (b) before 6pm. In addition, Unilever had manually reviewed the programming around which the ads appeared to ensure it was thematically appropriate.
We considered the issues raised in the ads, and the emotive imagery used, could have been upsetting for some children to see, particularly if they had direct experience of eating disorders themselves or through family and friends. However, the actions taken by Unilever limited the likelihood of children viewing the ads or seeing them unaccompanied.
On that point, we investigated ads (a) and (b) under BCAP Code rules 1.2 (Social responsibility), 5.1 (Children), and 32.3 (Scheduling), but did not find them in breach.
3. Not upheld
Love Island was a reality dating show that was broadcast after 9pm. We understood the programme had been a touchpoint in contemporary debates about body image and social media, and that Unilever had specifically placed ads (a) and (d) during Love Island due to those debates. They had also discussed the placement with ITV to ensure they were not scheduled alongside other ads that might contradict their message.
The ads attempted to raise awareness of harmful social media content and its relationship to issues with body image and eating disorders by directly recreating such content and then contextualising it in a manner that highlighted that support was available and that recovery was possible for those affected. We considered the audience for Love Island were likely to understand that the theme and content of the ad may be directly relevant to some viewers of the programme, be it in relation to an adult affected by an eating disorder, insecurities around their body image, or to support a child in their care. We therefore concluded the ads had not been inappropriately placed during Love Island.
On that point we investigated ad (a) under BCAP Code rules 32.1, and 32.3 (Scheduling), but did not find it in breach.
On that point, we investigated ad (d) under CAP Code (Edition 12) rule 1.3 (Social responsibility), but did not find it in breach.
Action
No further action necessary.
BCAP Code
1.2 4.1 4.10 5.1 32.1 32.3 32.3
