Gambling advertising and ‘lockdown’

Apr 8th '20

The COVID-19 crisis means we’re all spending much more time at home. Online entertainment is now an even more important way for us to unwind and pass the time. This has given rise to concerns over online gambling and how irresponsible marketing might encourage risky behaviour and how more time spent consuming media might lead to increased exposure to gambling marketing for under-18s.


The UK Advertising Codes are clear that marketing for gambling products must not be:


  • irresponsible in its use of content or themes that might exploit vulnerabilities; or
  • targeted through its content or placement at under-18s.


The Advertising Standards Authority (ASA) will take firm action against gambling advertising that does not meet these standards and will have due regard to the new context of the crisis and how it might affect consumers’ expectations and behaviour.


Gambling operators are warned to pay even more particular attention to their responsibilities under the Codes.


Encouraging consumers to report problems

The announcement of a formal national lockdown has led to consumer protection concerns. CAP recently launched a reporting process for people to quickly notify the ASA of marketing of mainly health-related products that take advantage of the COVID-19. This will allow swift action to be taken at a time of heightened risk for consumers.  Gambling advertising is no different.


Alongside our ordinary complaints processes, the ASA would encourage people to report gambling ads that:


  • refer to the COVID-19 crisis or related matters, such as the government’s lockdown policy; and / or
  • include particularly irresponsible claims or themes that have a direct relevance to the present situation (e.g. ads that refer to relieving boredom, repeated play or personal problems like family difficulties).


No ordinary times

Ads taking this kind of approach are likely to raise compliance issues under the UK Advertising Codes. In the present circumstances we are all anxious and potentially vulnerable; firm action will be taken against irresponsible messaging in gambling advertising. To this end, we will continue our close working relationship with the UK’s gambling regulator, the Gambling Commission, to identify issues and enforce compliance.


Setting standards, tackling irresponsible ads

The Committee of Advertising Practice (CAP) has published extensive guidance on its rules that protect adult audiences from irresponsible ads. It sets out the kinds of approaches in gambling advertising that are likely to be irresponsible; primarily because they exploit people’s vulnerabilities or encourage irresponsible behaviour.


The ASA will pay particular attention to the context of the present crisis and its effect on people viewing gambling ads. Areas of particular concern include ads that:


  • trivialize gambling (e.g. encourage repetitive or frequent participation);
  • refer even indirectly to indicators of problem gambling behaviour (e.g. solitary play, playing late at night, pre-occupation with gambling or isolating oneself from others;
  • refer to personal problems (e.g. that gambling can provide an escape); and
  • seek to exploit financial concerns


Limiting exposure for under-18s

The other key protections in the Codes prohibit targeting of under-18s. Gambling ads must not:


  • appear in media for under-18s;
  • appear in other media where under-18s are likely to comprise more than 25% of the audience; or
  • be targeted at those who are known to be or are likely to be under-18 through the use of data such as that available in media like social networking sites, video sharing platforms and online display ad networks.


The ASA recently carried out compliance and enforcement activity based on avatar technology. This allows us to accurately simulate a child’s online browsing profile to assess the ads served to it. Most gambling operators were found to be in compliance with CAP targeting rules; there were however breaches, which the ASA took action against.


The ASA will be repeating this kind of technology driven compliance work at several points this year and gambling will again be a key focus, and will again take firm action where breaches of the targeting rules are identified.


CAP has published guidance on the rules protecting under-18s.


Going forward

Gambling operators are warned to pay particular attention to their responsibilities to comply with the UK Advertising Codes. Along with ASA/CAP usual enforcement work, and will take swift action against ads that, in the context of the present crisis, are likely to exploit people’s vulnerabilities or encourage irresponsible behaviour.


Source ASA & CAP


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