If the poetically-monickered child psychologist’s predictions come true, spring 2009 looks like being crunch time for the UK’s online and computer games advertisers. Why and just what did the Review of Children and Technology say about advertising? Stephen Groom reports.
Who: Dr. Tanya Byron
When: April 2008
Law stated as at: 30 April 2008
The protection of children in the media was high on the agenda in the early spring of 2008, with publication of the Report of the Byron Review of Children and Technology.
The centrepiece of the Report was a proposed new body dubbed the "Council for Child Internet Safety" -cue cries, depending on your point of view, of "Oh no, not another quango", "What a good wheeze", "More jobs for the idle great and good", "That's got that hot potato kicked into the long grass for another year or so" or "Just what Dr Byron ordered."
All fine and dandy and predictable, but what did Lady Byron have to say that might be of interest to advertisers and marketers?
Well, there are well worked sections on both advertising of video games and on digital marketing and children. What did they conclude?
Focus on age-restricted computer games
To help step up efforts to ensure "age-appropriate gaming," as the Report puts it, it is recommended that alongside various measures aimed at a clearer game classification system, "the advertising and video games industries work together to improve guidance on the appropriate targeting and content of video games adverts in line with age classifications. I also make suggestions for specific measures they should consider".
These measures include steps to be taken in store to inform buyers about game classification systems and also the commissioning by HM Government of a separate enquiry.
This time the questions to be researched would be:
- whether video games are being advertised responsibly, in line with age ratings and
- the role of marketing in stimulating childhood and young people's desire to play video games which are not appropriate for their age.
This research, the Report suggests, should be conducted in partnership with the advertising and video games industries and in conjunction with another enquiry.
The enquiry in question is the Government's already commissioned assessment, under the auspices of its wide ranging "Children's Plan," of the impact of the commercial world on children ("Commercial World and Children Enquiry") "so that by Spring 2009 Government can take stock of the evidence and progress and encourage further action." There is more on the Commercial World and Children Enquiry below.
Harmful ad activity online
Next up, in the wider context of "harmful or inappropriate advertising content online," the Report expresses concern that online advertising could be both a form of inappropriate content (for example exposure to inappropriate text, image, products or services such as an advert for a dating service or an advert for a film which uses violent imagery"), and inappropriate contact or conduct (for example advertising competitions asking the audience to enter their personal details)."
There was also a related concern amongst respondents to the consultation which preceded the Report about the "sheer volume and format of adverts presented to children when surfing the internet."
In this context, the Report deferred again to the Commercial World and Children Enquiry, which kicked off in December 2007.
In this enquiry, the Report says, "leading academics will examine the available evidence about changes in the commercial environment …with the aim of building a consensus on the nature and extent of the impact of commercialisation in the round…looking at the benefits children gain from commercial engagement."
This assessment will apparently take approximately a year to complete and the process will consist of the now tried and trusted sequence of calls for evidence, consultations and commissioning of new research.
Online ad placement issues
Returning to what might be considered now by way of next steps, the Report focuses on online advertising and marketing.
Where there are CAP Code controls, for instance over targeting inappropriate and age restricted products at children, the Report also notes that media owners, in their responses to the Byron consultation, threw some mud in the direction of advertisers by raising "concerns about the lack of understanding from advertisers of their obligations under the CAP Code."
Media owners' "safety net" role?
Occasionally, the media owners said they had to act as a "safety net" to prevent the viewing of an inappropriate adverts by children. For example an advertiser might not understand online viewing figures and want to place an ad for an age-rated product in a part of a site that is viewed by children.
In light of this, the Report specifically recommends that "the advertising industry works with media owners to raise awareness amongst advertisers of their obligations under the CAP Code to advertise responsibly to those under 18 on the internet."
The Report also suggest the new Child Internet Safety quango should take account of this in its strategy and keep it under review.
Much online advertising outside CAP/ASA system
A related concern was over the categories of advertising and marketing online which could be harmful to kids but was currently outside the remit of the CAP Code and the Advertising Standards Authority.
One example was the marketing of unhealthy foods, another was the wider category of non banner ad website content that currently was not regulated by the CAP Code at all. Here the Report cited the 90% of complaints it received about online advertising in 2006 that the ASA had no authority to investigate. Disappointingly there were no figures yet available for 2007, but the strong suspicion is that this figure may well have grown.
Here the Report states that the ad industry is indeed taking steps to deal with this. And yes, you guessed it, it's another consultation/enquiry.
One initiative is the establishment of the Digital Media Group, an industry initiated task force reviewing the current self regulatory for digital advertising. The Report says optimistically that "the DMG will advise on and recommend a practical, fair and robust system for self regulation of advertising on digital media."
The DMG proposals, the Report continues, will cover the likely remit, funding and method of enforcement of such a system and also how the system can "progressively develop as the media develop." The DMG apparently hopes to finalise its proposals by September 2008 and to report shortly thereafter in line with the timings for yet another review.
This is the current ongoing review of all the CAP advertising codes to ensure that they are "fit for purpose" in the digital age.
In light of these developments the Report recommends that:
- the advertising industry take steps, mainly by way of the CAP Codes review, to "futureproof" the current system for regulating advertising, especially in relation to digital advertising
- consideration be given to how promotional marketing in non paid-for online space can be brought within the regulatory framework for advertising, inline with the principles o the prevention of harmful and offensive advertising to children already in the CAP Codes.
Why this matters:
The bottom line here is that Spring 2009 looks like being crunch time for the UK's online and computer games advertisers.
By this time, if Lady Byron has her way, the new Council for Child Internet Safety will be considering the end results of no less than four inter-relating and overlapping enquiries and recommending perhaps more child advertising codes, maybe more legislation in this area or perhaps, just to keep the pot boiling and the review/enquiry industry in action, more enquiries.
In the meantime it is to be hoped, joking aside, that to ward off unwelcome further legislation, UK digital and computer games advertisers will heed this important Report and act ever more responsibly where children are concerned.