Ad description
A website, www.virginholidays.co.uk, and Virgin Holiday's Facebook page, featured a competition for a holiday:
a. The website was headed "WIN 4 Weeks of Holiday" and featured an image of a female's tanned stomach and arm. The text "THE #Tanuary SALE" was stated on the woman's torso in an area that had not been tanned. Text beside the image stated "Win 4 WEEKS OF HOLIDAY". Beneath the image, text stated "Got a tan line Pic? Show us your white bits and you could win 4 weeks of holiday. Upload to Twitter or Instagram using #Tanuary to enter and you will be entered into our BIG PRIZE DRAW".
Further text beneath the sub-heading "# Tanuary Tattoo Bonus Prize" stated "Are you daring enough to show us your white bits? Go further and pick up one of our #Tanuary tattoo stencils from one of our retail shops or v-room lounge pre departure, apply the tattoo to your skin before you hit the beach, and it will leave a '#Tanuary' on your perfectly bronzed skin. Upload a photo on Instagram/Twitter, tagging #Tanuary for the whole wide world to see and you will be in with the chance to win our 5V Bonus spot prize ... ". Beside that text was a photograph of a female's tanned hip with the "#Tanuary" logo that appeared in an area that had not been tanned. Text beside the photograph stated "WIN WITH OUR #TANUARY TATTOO".
b. The ad on the advertiser's Facebook page featured a female's tanned hip with the "#Tanuary" logo. Next to the image, text stated "WIN WITH OUR #TANUARY TATTOO". Text underneath the image stated "Virgin Holidays. We're giving you an extra chance to win. Grab a suntan tattoo from one of our retail stores or the v-room, then hit the beach, bronze up and upload your #Tanuary tan line pic for all to see. You could win a trip to Dubai. Details here: [link]".
Issue
Two complainants challenged whether the ads were irresponsible, because they believed they encouraged consumers to tan their skin without raising awareness of sun safety.
Response
Virgin Holidays Ltd believed the ads had been prepared with a sense of social responsibility to consumers. They said prior to the launch of the "Tanuary Sale" competition, Virgin Holidays and a skin cancer charity communicated their partnership to promote sensible tanning. They said that throughout the promotion the header on their website included an icon that stated "Please tan responsibly". They said the header clicked through to a page that explained their partnership with the skin cancer charity and provided a link to a further website dedicated to sun safety. They said entrants who had submitted entries of sunburn were told by Virgin Holidays that their entries had been rejected and were provided information about the need to tan responsibly. They said the #Tanuary tattoo stencils that were available featured the "Please tan responsibly" message.
Facebook said the ad did not violate their guidelines.
Assessment
Upheld
The ASA understood that prior to the launch of the "Tanuary Sale" competition, Virgin Holidays communicated their partnership with a skin cancer charity to promote sensible tanning.
We noted both ads featured images of a woman's tanned torso with the text "#Tanuary" that appeared in an area that had not been tanned.
We understood the header on the website included an icon that stated "Please tan responsibly" and clicked through to a website dedicated to sun safety. We noted ad (a) was headed "WIN 4 Weeks of Holiday" and invited people to submit photographs showing their tan lines to win. The ad also questioned "Are you daring enough to show us your white bits?" and invited consumers to "Go further and pick up one of our #Tanuary tattoo stencils ... apply the tattoo to your skin before you hit the beach, and it will leave a '#Tanuary' on your perfectly bronzed skin".
Whilst we acknowledged ad (a) included an icon that stated "Please tan responsibly" and clicked through to a website dedicated to sun safety, we were concerned that the information was not given sufficient prominence. In particular, we noted the icon was significantly smaller than the headline claims which promoted the opportunity to win a holiday. We also considered the large prizes on offer were significant incentives for entrants to acquire a tan.
We noted ad (b) did not refer to sun safety and invited consumers " ... to hit the beach, bronze up and upload your #Tanuary tan line pic for all to see" for the chance to win a holiday.
We therefore considered the ads could encourage recipients to tan their skin without giving sufficient prominence to information about sun safety. On that basis, we concluded that the ads were irresponsible and therefore breached the Code.
The ads breached CAP Code (Edition 12) rule 1.3 1.3 Marketing communications must be prepared with a sense of responsibility to consumers and to society. (Social responsibility).
Action
The ads must not appear again in their current form.
