Title: CAP Guidance on Children and Age-Restricted Ads Online
Who: Committee of Advertising Practice (CAP)
When: 6 June 2017
The UK’s ad regulator views children as extremely susceptible to advertising and sees it as important to ensure that they are adequately protected from unsuitable inappropriate ads. As a result, some ads are age-restricted such that they cannot be placed in media directed at children or in media where children make up a significant proportion of the audience.
The rise of digital media and the prevalence of social media amongst children, have introduced fresh challanges in this regard. As a result, CAP has released new guidance to assist marketers to show that “they have taken reasonable steps to target age-restricted ads appropriately so as to minimise children’s exposure to such ads online, including on social media.” Although the guidance is aimed at age-restricted ads, CAP has indicated that it could be helpful generally for other marketers as well.
The main concern for CAP is the potential unreliability of using advertising data in isolation to target ads to particular age groups. CAP encourages marketers to make use of the demographic data made available to them (for example when users sign up or login in to a service) to target age-restricted ads appropriately. However, such data is not always 100% reliable for age targeting purposes – people often use others’ online devices and children may misreport their age for social media.
As a result, CAP’s new guidance aims to ensure that marketers also use interest-based factors (i.e. data on what users frequently search, browse or share online) to further refine the group of people exposed to their ads. CAP suggests targeting age-restricted ads to groups of users over a certain age who also have shown interests in particular things. The logic is that even if a teenager misreports their age on social media, they are still likely to have an interest in things or themes which are appropriate for their true age which they demonstrate online.
The guidance states that marketers should take “special care” to ensure that they are able to support the demographic data they have with behavioural data on their users’ likes/dislikes to define their target audience and that they should exclude interests strongly associated with people in age-restricted categories. CAP’s guidance adds that if the target audience is close to the threshold for age-restriction for a particular ad, marketers will have to show that they took even more care to adequately target their ads.
Why this matters:
This guidance increases the burden on advertisers to make sure that they are accurately targeting online ads. If the ASA receives a complaint, it will expect to see evidence that the marketer has also targeted by reference to interests that resonate with individuals that are older than the restricted age group.