“Letting children be children” is the title of a report published by the Department for Education on the commercialisation and sexualisation of youngsters. Advertising predictably comes under scrutiny and Judith Gordon kids us not as she reports the key ad findings and recommendations relevant to marketers.
Who: UK Government Department for Education and Reg Bailey
When: June 2011
Law stated as at: 5 July 2011
On 6 June 2011, Reg Bailey (Chief Executive of the Mothers' Union) published his report of an independent review of the commercialisation and sexualisation of childhood (the "Review").
The report followed 6 months of research after Bailey was asked in December 2010 by the coalition government, to assess how children in the UK are being pressured to grow up too quickly and to make recommendations on how to address public concern about this. Though focusing largely on the opinions of parents, Bailey also spoke to children and young people, businesses and organisations, experts and members of the public generally.
The Review identified the following four key themes as being of particular concern to parents:
1. Sexualised images forming the 'wallpaper' of children's lives
2. Inappropriate clothing, products and services for children
3. Children as consumers
4. Making parents' voices heard
The Review examines each of these themes in detail, highlighting parental concerns and stating what action they would like to see in the area, backed with a series of recommendations.
Key findings of report in relation to advertising
Theme 1: the Review states that its goal under this theme is to see that sexualised images used in public places and in various media sources, become more in line with what parents find acceptable and that public space becomes more family-friendly.
To this end, it recommended a reduction in the amount of on-street advertising containing sexualised imagery in locations where children are likely to see it. Referring to the social responsibility clause 1.3 of the Advertising Standards Authority ("ASA")-enforced CAP Code of Non-broadcast Advertising, Sales Promotion and Direct Marketing, the Review stated that advertisers should take account of this when considering the placement of sexualised advertisements near schools (in the same way that they already do with alcohol advertisements for example) and further recommended that the ASA place stronger emphasis on the location of an advertisement too, as well as the number of children likely to be exposed to it.
Theme 2: the Review states that it would like to see that retailers do not sell or market inappropriate clothing, products or services for children.
Bailey recommends that a voluntary retail code of practice is developed by retailers and their trade associations, in relation to selling to children.
The British Retail Consortium in fact pre-empted this recommendation somewhat and on the same day as Bailey's Review, published their own 'good practice' guidance for stores selling children's clothing. Linked to Theme 1, the Review highlighted parents' concerns with clothes bearing suggestive slogans or girls' cloths in particular, being marketed in a sexualised way.
The guidance covers garment styles, fabrics and marketing, and has been produced with several key retailers.
Theme 3: the Review states that it would like to see comprehensive and effective regulatory action protecting children from excessive commercial pressures; ii) that marketers do not exploit any gaps in advertising regulation in order to unduly influence the choices children make as consumers and iii) that parents and children have a sound awareness and understanding of marketing techniques and regulation.
The key recommendations under this theme in relation to advertising are that:
- the ASA should conduct research with parents and children so as to obtain feedback on their approach to regulation and their decisions, with the results of this research to be published in their annual report;
- the employment of children as brand ambassadors and in peer-to-peer marketing should be prohibited;
- the ASA should also conduct research with parents, children and young people, in order to determine whether the ASA should always define a child as a person under the age of 16 (in line with the CAP and BCAP); and
- the advertising industry and the ASA/AA should work with parents to improve awareness of marketing and advertising techniques, regulation and complaints processes.
Theme 4: the Review states that it would like to see that parents find it easier to raise concerns, and that these concerns are listened to more readily and followed up with action from businesses and regulators.
The Review recommends that pursuant to this aim, a single website is set up for all regulators that clearly sets out what parents can do if they feel that a programme, advertisement or product/service is inappropriate for children. The site would contain links to the relevant complaint forms on individual regulator's sites, as well as be an outlet for findings on general parental feedback in the area.
A further recommendation asks that businesses marketing goods or services to children have a one-click link to a complaints service on their home page, with related information making clear that comments/complaints from parents.
The Prime Minister has thrown his support behind the report and in an open letter to Bailey, wholeheartedly agreed with the assertion that we should "look to put the brakes on an unthinking drift towards ever greater commercialisation and sexualisation".
Cameron suggested a meeting in October with Bailey and other interested parties to discuss how to progress the report's findings, however felt that the recommendations in relation to the single site for parents' complaints and feedback could be set up without delay.
The ASA was quick to respond to the report and immediately published a short response on its website, stating that it "welcomed" the advertising recommendations and cited its ongoing commitment to the protection of children from harmful or inappropriate material.
Guy Parker, the Chief Executive of the ASA, has subsequently admitted to the difficulties in applying similar restrictions to sexualised billboards as are already applied to alcohol advertisements, given how much more subjective 'sexualised' ads are, and referred to the "potential for inconsistency". Thus whilst the ASA appear to be getting behind Bailey's recommendations, it is unknown at present how far they will go in taking these on board in terms of regulation in this area.
Ad industry feedback
The reaction of the ad industry as a whole appears to be cautious: marketers are keen to get behind the principles involved in the debate however see obstacles to implementing the recommendations.
The relief that came with the publication of the report, and the recommendation that this is a matter for society, business and parents to work together on, instead of through statutory regulation, appears to have been short lived as industry commentators are sceptical of the practicalities of some of Bailey's recommendations.
Ruth Mortimer, MarketingWeek's associate editor, in particular referred to the statistics in the Review, which actually suggest that not as many parents as Bailey implies take issue with the over-commercialisation of their children.
The Advertising Association has responded with the creation of a panel to address the issue of marketing to children and has made key hires such as Mark Lund (former COI chief executive) and Ian Douthwaite (boss of marketing agency Dubit).
Why this matters:
With research showing that 88% of parents think that children are under too much pressure to grow up and staunch support from the government, this is an issue that isn't going to go away any time soon.
Advertisers need to be seen to be taking Bailey's recommendations on board and it remains to be seen whether specific regulatory reforms will be the final result of this process.