Who: The Advertising Standards Authority (ASA)
Where: United Kingdom
When: 19 July 2023
Law stated as at: 11 August 2023
What happened:
On the 29 November 2022, the ASA published The 100 Children Report, where it monitored the personal devices of around 100 children and young people in between the ages of 11-17 over seven days to uncover the types of age-restricted ads to which they were exposed. The report sought to challenge and evaluate the perception that children are being “bombarded” with age-restricted ads online, for things like alcohol, gambling and other age-restricted products and services. Following the report’s publication, the ASA undertook to engage with the advertising industry on some of the key findings and has done so via the publication of The 100 Children Report – enforcement and engagement report.
This follow-up report focused on the following areas:
- ASA engaged with advertisers, agencies and social media platforms in relation to occasions where age-restricted ads were served to children in clear contravention of the UK Code of Non-broadcast Advertising and Direct & Promotional Marketing (CAP Code). It was found that the majority of these ads were for gambling and alcohol products.
- Children presenting as adults. The ASA engaged with advertisers where their ads were served to children who falsely reported their age as 18 plus. The ASA explained that advertisers are expected to use a range of audience and media targeting tools (such as “interest” based selections) to ensure that age-restricted ads are not targeted at audiences with interests typically associated with children.
- Engagement with online platforms. The ASA engaged with large online platforms regarding the service of age-restricted ads to children that signified that they were 17 or younger.
- Measures taken by advertisers and agencies. The ASA reviewed the provision of information, from advertisers and agencies, which indicated the steps they have taken to comply with CAP guidance to limit children’s exposure to age-restricted ads. These measures included age-restricted accounts, proactive exclusion of ads based on key words, and use of automated scripts to identify if ads have been incorrectly configured without age restrictions in place and periodic spot checks.
- Online platform policies. The ASA reviewed information regarding the policies that platforms have in place to support advertisers and agencies in complying with advertising regulation. They also received specific submissions from big tech providers, outlining the policies that those platforms have in place to support compliance with advertising regulation in relation to media placement and audience targeting restrictions.
Why this matters:
The publication of this follow-up report reflects that ASA’s ongoing commitment to its zero-tolerance approach to age-restricted ads being shown to children. The sentiment of the report indicated that the advertising industry has engaged positively on this topic and, as such, no particular advertisers were named and shamed. The report also serves as an important reminder that the ASA will continue to capitalise on new technologies to support its approach to enforcement and that self-initiated projects of this nature are likely to become more commonplace. This is likely to not only shape the regulatory landscape in the world of advertising, but also the broader digital regulatory environment.
