Monday, July 21, 2014

Let's Talk About Age Appropriate Advertising Shall We?

A month or so ago I was browsing the Hoyts website looking at session times. I was intrigued to find that on a Sunday morning they run Hoyts Junior sessions that feature movies such as Dora the Explorer and Thomas the Tank Engine. It seemed like a great opportunity to let Maddy and the Husband see an older movie together while I took the littlies to a junior movie and use up a series of expiring vouchers.

Can you imagine my surprise to find this advertisement on the Dora the Explorer page? Miss 3 year old Lorelei was sitting on my lap watching the Dora preview at the time that I noticed it and 13 year old Madeleine was passing in and out of the room as we planned our sessions.

I'm no prude. I've spotted this product before on the Groupon site a few times and found it intriguing that there is a market via the group buy sites for products of this nature. In my Groupon browsing I think I've even clicked on it either directly on the site or through from the newsletter. As adult advertisements go it is reasonably tame.

But I was not impressed to find that the idle browsing I had performed on Groupon would somehow be following me by appearing on future Internet sessions. We all know this happens, I can't count how often a company whose page I have just visited suddenly appears as a sponsored post in my Facebook feed, or as an advertisement on another page entirely. I don't care about advertising or adult products one way or the other as a general rule, but adult product marketing needs to be contained to sites where you would expect a solely adult audience. End of story.

I made a point of lodging a complaint with the Australian Standards Bureau, because I would like to think that I can both browse websites as tame as Groupon and Hoyts without worrying about unfriendly content, but also allow my 13 year old to use the same computer as me. The computer that I do not make a habit of using to browse for pornography or adult content.

This was my complaint.

This advertisement was positioned to appear on the same page (any many others) as a Dora the Explorer movie blurb and video. Dora the Explorer is rated G, and is targeted towards younger children. I have no issue with the product advertised, but expect advertisements for products of a sexual nature to not be in the same location as marketing for a child. My young child was sitting on my lap watching the video when I noticed the advertisement, and my 13 year was also looking over my shoulder as we chose movie sessions and times together. This was not appropriate content for either of them and not something I expected to come across on the Hoyts website when looking at a child’s movie. I do have a screenshot available of the advertisement; as I note it does not seem to consistently appear.

This is the response from Groupon to the ABS.

Generally speaking, Groupon does not purchase advertising space on websites, and certainly the advertisement which is the subject of the complaint was not placed on the Hoyts website in the traditional sense of media buying. The advertisement was generated dynamically. This means that the advertisement was generated based on the complainant’s web browsing history and would not have appeared to generic visitors to the Hoyts website.
It is most likely that the complainant had previously visited the Groupon website and viewed a listing on that site for the product in question; consequently cookies used by Groupon result in the complainant being specifically targeted with pop up advertisements for products previously viewed by her as she continues browsing the Internet, in the same or subsequent browsing sessions.
In regard to Section 2 of the Australian Association of National Advertisers (AANA) Code of Ethics, we are of the opinion that the advertisement is not explicit, exploitative or degrading to any individual or group of people, nor does it refer to sex or nudity in an insensitive way. Furthermore, we do not believe the advertisement should be considered as a Marketing
Communication to Children according to the definition contained in the AANA Code for Advertising and Marketing to Children; as explained above, the advertisement was not directed at such an audience in any way.
Notwithstanding the above, we do wish to ensure advertisements for such products are targeted in the most appropriate way and on becoming aware of the complaint we took the step of blocking all adult products from re-targeting so as to ensure advertisements are not directed to an age-inappropriate audience or in close proximity to content which appeals to such a demographic.

I can appreciate their position. They didn't directly purchase the advertising space on Hoyts, and did not take into account the possible placement of their advertising as a result of tracking my browser cookies. Fair enough, and I appreciate that they have removed the re-targeting of adult products as a result of my feedback.

This was the response from the ABS though, which is the bit that has me irritated.

The Advertising Standards Board (“Board”) considered whether this advertisement breaches Section 2 of the Advertiser Code of Ethics (the “Code”).
The Board noted the complainant’s concerns that the advertisement features explicit sexual material which is not appropriate for children to see.
The Board viewed the advertisement and noted the advertiser’s response.
The Board considered whether the advertisement was in breach of Section 2.4 of the Code. Section 2.4 of the Code states: “Advertising or Marketing Communications shall treat sex, sexuality and nudity with sensitivity to the relevant audience”.
The Board noted the advertisement is for a female sex toy and includes the name of the product and a picture of a woman lying on a bed.
The Board noted it had recently dismissed a similar online advertisement for an adult product in case 0190/14 where:
“The Board noted that the advertisement does contain sexual material which many members of the community could find to be offensive and/or inappropriate but considered that in order to view the material you would have to choose to do so. The Board noted that the additional
information is presented in a manner which is informative and considered that the diagrams used are clinical rather than sexualised. The Board considered that in the context of an advertisement which is provided to subscribers only and that is able to be seen once the subscribers chooses to get more information about the product the advertisement does treat the issue of sex, sexuality and nudity with sensitivity to the relevant audience.”
In the current advertisement the Board noted the advertiser’s response that the advertisement was generated on the Hoyts page due to the complainant’s browsing history as the advertiser does not purchase advertising space on websites. The Board noted that the advertiser had taken steps to ensure that the re-targeting of these types of advertisements on websites such as Hoyts could not happen in the future.
The Board noted that the relevant audience for Hoyts is either a parent searching for information about a movie for themselves or a child. The Board considered that a child that likes Dora would not understand the advertisement for a vibrator.
The Board noted that notwithstanding how the advertisement came to be displayed on the Hoyts website, in the Board’s view the image of the woman is relatively mild: her private areas are all covered and she is not posed in a sexualised or inappropriate manner. The Board noted the wording of the advertisement features the product name and price and considered that overall the advertisement does treat the issue of sex, sexuality and nudity with sensitivity to the relevant audience.
The Board determined that the advertisement did not breach Section 2.4 of the Code. Finding that the advertisement did not breach the Code on other grounds, the Board dismissed the complaint.

In case you didn't want to read all that, the complaint was dismissed. It is considered acceptable to market adult goods alongside Dora the Explorer because the owner of the computer has previously browsed the product and a child interested in Dora the Explorer would not be old enough to understand the advertisement.

I'm just going to call bullshit on this decision. I appreciate Groupon's actions resolve my complaint, however I'm stunned that Australian standards consider this to be acceptable. In other words, it would be OK for Groupon, or any other company, to continue to place advertising for adult products on pages that offer content for my young children.


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