An online game operated by Kellogg’s and targeted at young adults could only be entered via the Facebook page of Kellogg’s chocolatey cereal Krave. A complaint was made to the ASA that the game encouraged poor nutritional habits in children. Omar Bucchioni suspends his Lent chocolate ban to report.
Topic: Social media
Who: Advertising Standards Authority (ASA) and Kellogg Marketing and Sales Company (UK) Ltd
When: February 2012
Where: UK
Law stated as at: 29 February 2012
What happened:
Recently, the Advertising Standards Authority “ASA” has investigated an online game, seen on Facebook on 31 October 2011 which promoted “Krave”, a breed of new cereal from Kellogg’s. The aim of the game was to guide the character, Krave, dressed as a superhero, over platforms, by jumping over gaps and household obstacles to chase and jump on pieces of chocolate.
Sustain, (www.sustainweb.org) an alliance for better food and farming which represents around 100 national public interest organisations working at international, national, regional and local level, challenged whether the game encouraged poor nutritional habits and an unhealthy lifestyle in children.
Clause 15.11 of the CAP Code states: “Marketing communications must not condone or encourage poor nutritional habits or an unhealthy lifestyle in children”.
What Kellogg’s had to say
Kellogg’s (www.kelloggs.co.uk) said that Krave cereal was aimed at a young adult audience and was marketed through young adult channels such as late-night TV advertising and sampling on university campuses.
Any digital advertising was directly targeted at young adults only by actively taking steps to prevent a person under 17 entering the game by placing it in environments that had built-in age gates i.e. the game was only accessible via the Krave Facebook page, or via smartphone download from the Krave website.
To play the game on Facebook, a user needed to be logged into their Facebook profile, and Facebook checked their existing Facebook profile information to ensure they were 17 years of age, before they could click through to play the game.
The age information used was that provided when users set up their Facebook account which could well have been a very long time before, when no incentive to input an incorrect age existed.
The prizes were also designed to appeal to adults i.e. adult sized T-shirts and sweatbands being among them.
What the ASA had to say
The ASA considered Kellogg’s comments and noted that users were required to log in to their Facebook profile to play the game. It also noted that Facebook checked a user’s date of birth in their profile information before allowing them to play.
The ASA also noted that a user’s date of birth was input into Facebook when the account was set up, which was likely to have been some time before the user attempted to access the game, and before the user had a reason to misstate their age.
The CAP Code defines a child a person under 16 years of age. Since Kellogg’s had taken steps to ensure that people under 17 could not access the game, the game was not aimed at children and, therefore, it was compliant with the CAP Code since it did not encourage poor nutritional habits or an unhealthy lifestyle in children.
Why this matters:
From 1 March 2011 the UK Code of Non-broadcast Advertising, Sales Promotion and Direct Marketing (the CAP Code) applies in full to marketing messages online, including the rules relating to misleading advertising, social responsibility and the protection of children.
It is important to remember that the ASA’s remit has therefore been extended to cover:
- advertisers’ own marketing messages on their own websites
- marketing communications in other non-paid-for space under the advertiser’s control, such as social networking sites like Facebook and Twitter
- marketing communications on all UK websites, regardless of sector, type of businesses or size of organisation.
More information is available here.
