Audio description and other access services.
Audio description (AD) is an additional narration track provided alongside some audio-visual media services. The narration articulates what is happening on-screen for the benefit of blind and partially sighted audience members; for example, describing the movements and body language of characters in a drama.
Until recently, AD was available only on some broadcast editorial content via digital television and it was rare for broadcast and non-broadcast advertising to be audio described. However the Committee of Advertising Practice (CAP) and the Broadcast Committee of Advertising Practice (BCAP) understand that it is now becoming more common in advertising, particularly in broadcast media. CAP and BCAP recognise the benefits for inclusion that come with audio description, which are welcome: but it is important to ensure that the regulatory status of audio description is clear and the rights of blind and visually impaired members of the TV audience are respected.
The CAP and BCAP Codes apply to all aspects of advertisements within their remit. This includes AD or any additional content provided to improve accessibility; including signing and subtitling.
This does not mean that advertisers must audio describe their ads nor, when they do, that they need to describe all of the visual elements. However, when AD is added, blind and partially sighted viewers, and the Advertising Standards Authority (ASA) Council, might reasonably consider that the AD should include any essential visual elements, for example, on-screen text which qualifies spoken claims. For this reason not all ads may lend themselves to audio description, such as those which include large amounts of mandatory or qualifying on-screen text.
Ads which omit material information, making it difficult for consumers to make informed decisions about a marketer’s product or service, are likely to breach the misleading advertising rules in the CAP and BCAP Codes, which require that ads must not mislead by hiding material information or presenting it in an unclear, unintelligible, ambiguous or untimely manner. Limited time does not influence the requirement to provide that information in a clear and intelligible manner: it should be delivered at a pace that allows it to be easily understood.
Feedback from BCAP’s call for evidence on audio description indicates that, while blind and visually impaired members of the TV audience welcome the greater inclusion that comes with description of narrative detail, it is important above all to know what is being advertised and to have access to the same material information as other members of the audience. Advertisers should take care to avoid providing unnecessary detail at the expense of material information.
Where the ASA receives a complaint specifically about an ad with AD from or on behalf of a blind or partially sighted audience member it may well assess only the AD and other audio elements, and not the visuals, against the Code. These elements, taken on their own merits, should therefore not mislead, harm or offend.
Advertisers are advised to discuss the addition of audio description to broadcast advertising with Clearcast and to non-broadcast advertising with CAP’s Copy Advice team.