Published by the Department of Education in London.
3977566Letting Children be Children — Theme 32011Reg Bailey
THEME 3
Children as Consumers
"...a parent's job is made considerably more difficult by the constant bombardment of advertising and the pressure on children to be, do and have a bewildering variety of products and experiences ranging from music, games and clothes to holidays and outings. Even if this does not reach one's own child directly, it inevitably reaches them indirectly by means of peer pressure."
Parent, Call for Evidence response
Overview
We all live in a commercial world and children are under pressure from a range of sources to act as consumers.
We do not want to cut children off from the commercial world completely as we believe that it brings benefits and parents tell us that they want to manage the issue themselves, supported by proportionate regulation and responsible businesses.
While adults may understand that companies might look to 'push the boundaries' when advertising to them, children are especially vulnerable and need to be given special consideration.
Special measures already exist in advertising and marketing regulations to protect children but some gaps exist.
Regulators cannot realistically be expected to anticipate detailed developments in the new media. However, an absence of regulation does not absolve businesses from acting responsibly by themselves.
WHAT WE WOULD LIKE TO SEE
That the regulations protecting children from excessive commercial pressures are comprehensive, effective across all media and in line with parental expectations.
That marketers do not attempt to exploit any gaps in advertising regulation in order to unduly influence the choices children make as consumers.
That parents and children have a sound awareness and understanding of marketing techniques and regulation.
RECOMMENDATIONS
7.
Ensuring that the regulation of advertising reflects more closely parents’ and children's views. The Advertising Standards Authority (ASA) should conduct research with parents and children on a regular basis in order to gauge their views on the ASA's approach to regulation and on the ASA’s decisions, publishing the results and subsequent action taken in their annual report. ACTION: ASA
8.
Prohibiting the employment of children as brand ambassadors and in peer-to-peer marketing. The Committee ofAdvertising Practice and other advertising and marketing bodies should urgently explore whether, as many parents believe, the advertising self—regulatory codes should prohibit the employment of children under the age of 16 as brand ambassadors or in peer—to—peer marketing – where people are
paid, or paid in kind, to promote products, brands or services. ACTION: Committee of Advertising Practice, the Advertising Association and relevant regulators
9.
Defining a child as under the age of 16 in all types of advertising regulation. The ASA should conduct research with parents, children and young people to determine whether the ASA should always define a child as a person under the age of 16, in line with the Committee of Advertising Practice and Broadcast Committee of Advertising Practice codes. ACTION: ASA
10.
Raising parental awareness of marketing and advertising techniques. Industry and regulators should work together to improve parental awareness of marketing and advertising techniques and of advertising regulation and complaints processes and to promote industry best practice. ACTION: Advertising and marketing industry, with the ASA and the Advertising Association
11.
Quality assurance for media and commercial literacy resources and education for children. These resources should always include education to help children develop their emotional resilience to the commercial and sexual pressures that today's world places on them. Providers should commission independent evaluation of their provision, not solely measuring take—up but, crucially, to assess its effectiveness. Those bodies with responsibilities for promoting media literacy, including Ofcom and the BBC, should encourage the development of minimum standards guidance for the content of media and commercial literacy education and resources to children. ACTION: Media and commercial literacy providers, with Ofcom and the BBC
Introduction
1.
The commercial world is an inextricable part of our lives and our society. The complexity of the relationship between that world and childhood is well documented in the 2009 assessment for Government of the impact of the commercial world on children's wellbeing. The commercial world is valued for the benefits and opportunities it offers, but parents and parenting organisations express concerns regarding the pressure it is seen to exert (DCSF/DCMS, 2009; Phoenix, 2011).
2.
There is evidence that society is becoming increasingly commercialised (DCSF/DCMS, 2009; Phoenix, 2011). The market for goods and services for children is large and growing—estimated to be in the order of £100 billion a year if childcare and education is included–and there is some evidence that children's influence on family spending is increasing, as well as their own spending power (DCSF/DCMS, 2009). It is not surprising then if companies choose to appeal directly to children as consumers (Marketing magazine, 2011).
3.
From an early age, children are able to recognise the names of familiar people and objects as part of their normal development. It is therefore to be expected that if they repeatedly see a brand logo or hear its name they will be able to recognise and name it, especially the brands of companies popular with their family. Research in the Netherlands showed that 2 and 3 year-olds could recognise eight out of the 12 brands shown to them (Valkenburg and Buijzen, 2005). This means that even companies not overtly marketing to children can benefit from having their brands prominently displayed and easily recognised by the potential customers of the future.
4.
Children are also living increasingly 'media—saturated' lives, inevitably being exposed to an increasing volume of advertising and marketing as they watch television, go online, use mobile phones and smart phones, or play video games (see Figure 7).
Figure 7: Commercial Media Clock of a school day, ages 5-16 (self-reported)
Source: Childwise, the Monitor Report 2010-11, Children's media use and purchasing. (Reproduced in Advertising Association, 2011)
5.
Against this backdrop, the concerns of parents and others we heard from during this Review included:
social pressures on parents, peer pressure and 'pester power', as well as the volume of advertising and marketing;
the effectiveness of current advertising regulation;
inappropriate advertising aimed at (or seen by) children; and
'new' marketing techniques (especially those that use new technology).
Pressure to consume: peers, 'pester power' and parents
6.
Together with the marketing of brands as well as products, and the volume of merchandising accompanying popular television, film and book characters, parents are concerned that commercial practices contribute to a “layering” effect that can be overwhelming and which they fear is having a negative impact on family life.
7.
Children are increasingly using the internet (Ofcom, 2011(2)) and in doing so are exposed to a significant volume of marketing messages as social networking sites and other sites popular with Children become increasingly Parent, Call for Evidence response commercialised and companies spend more on online advertising. UK internet advertising grew 12.8 per cent in 2010, with the biggest gain being in display advertising, which grew by more than a quarter (27.5 per cent) to £945.1 million, including a nearly 200 per cent surge in display advertising in a social media environment (Internet Advertising Bureau, 2011).
"It is the cacophony of advertising messages everywhere that make it hard to escape."
Parent, Call for Evidence response
8.
In addition, alongside the development of integrated marketing strategies across the range of media channels, advertising and marketing techniques are increasingly sophisticated and often hard to distinguish from content: even older children find it hard to say whether advergames, for example, are designed to entertain or to persuade (Fielder, Gardener, Nairn and Pitt, 2008).
9.
It must be the case, then, that children are under more pressure from advertisers and marketers to consume than they have been in the past.
10.
However, some of this pressure is felt by children and parents more indirectly in the form of social pressure to conform to certain norms. Alongside factors such as value for money, educational qualities, and the longer—term potential for enjoyment and use of particular products, previous research (Phoenix, 2011), our Call for Evidence and our qualitative research suggest that key motivations for parents to buy non—essential items for their children are the desire to be seen by other parents as a good provider and for their children to have the same things and opportunities as their peers, or to prevent them from being teased or bullied.
"I feel pressure from other parents, like – that parent's done it, why haven't I and should I do it?"
"Sometimes if I 'm at work and I'm feeling guilty because I 'm at work... Then I might buy something. I'm guilty of purchasing things because of that."
Parents, Review qualitative research
"My eldest's school shoes and coat were bought out of us worrying that he may be bullied if it wasn't the right look."
"The problem is that parents sometimes feel the peer pressure too and often feel almost forced to buy certain products because other parents are. They feel like bad parents if they don't."
Parents, Call for Evidence response
11.
It is also clear that the persistence with which children ask for things is another influence (Phoenix, 2011). Children and young people freely acknowledge their use of 'pester power':
Nearly a third (32 per cent) of children in the omnibus survey for the Review say that if they really want something and they know their parents do not want them to buy it, they will always keep on asking until their parents let them have it. More than half (52 per cent) say they sometimes do this and only 15 per cent said they never do (Figure 8).
Over three quarters of children and young people who responded to a survey run by the Children and Young People's Advisory Group of the Office of the Children's Commissioner (Children's Commissioner and Amplify, 2011) thought that children and young people put pressure on their parents to buy things for them.
Figure 8: Children's use of ‘pester power’ (self-reported)
If you really want something and you know your parents don't want you to buy it, do you ever keep on asking for it until they let you have it?
Source:TNS Omnibus Survey, 2011 Weighted base: 520 children aged 7-16 in Great Britain
12.
Children in their turn are influenced by their friends and what is popular at school: the large majority of the children and young people in the Office of the Children's Commissioner for England's survey thought that children and young people are under pressure to own certain items. Most said that it was because they wanted to fit in, look cool, because of peer pressure or to not feel alone, and some said it was to avoid the risk of bullying or people making comments (Children's Commissioner and Amplify, 2011). In the omnibus survey for this Review, children ranked their friends having or liking something second only to price in a list of factors influencing their buying decisions. And 57 per cent of children surveyed said that they had bought or asked their parents to buy them something just so that they would be the same as their friends.
"If you don't have something other young people will make fun out of you or you feel left out when everyone else is using it."
"People want to fit in with their friends and don't want to feel left out."
Young people, Office of the Children's Commissioner for England survey
Figure 9: Factors influencing children's choice of clothes, toys and gadgets
Thinking about when you go shopping for clothes, toys or gadgets, which of the following things help you decide which ones to choose?
Source:TNS Omnibus Survey, 2011 Weighted base: 520 children aged 7-16 in Great Britain
13.
This echoes the views of children taking part in focus groups as part of the research for a report to the Scottish Parliament, who considered peer pressure to be much greater than pressure from stores or manufacturers or through images of celebrities:
"Both for boys and girls, having the 'right stuff'–in the form of branded goods, with labels and logos clearly displayed–was critically important in terms of self-image and peer group status."
Buckingham, Willett, Bragg, and Russell, 2010
14.
So children are undoubtedly under a great deal of pressure to consume. But the parents we heard from clearly feel that it is up to them, with support from other parents, to resist, and to help their children resist, these sorts of pressures, and to say 'no'.
"Whilst talking about this to parents, many have said they buy things in order for their children not to feel left out. I feel that many parents would like to know what other parents do in these situations."
"I do often check in with other parents as to what they are being asked for and what boundaries they are willing to enforce."
"You have a choice as a parent, as an adult. If you don't like it, don't let them (have it)."
Parents, Call for Evidence response
15.
However, they also feel that this would be easier if businesses were more responsible towards children and more parent—friendly to begin with.These feelings find an organised expression in campaigns such as the Bye Buy Childhood (Mothers' Union, 2010), Let Girls Be Girls (Mumsnet(2)) and others, but were also brought out by parents’ evidence for this Review.
"I am still old fashioned enough to think that the primary responsibility for the actual purchases remains with the parents who can just say no. But others can make the pester power less powerful."
Parent, Call for Evidence response
"The advertisers say they don't target children, but they do."
Parents, Review qualitative research
"Parents do say no. They say no, you can't stay up late. No, you can't eat pudding before your main course. No, you can't have a dog. Setting boundaries is what parents do. It's tough sometimes... and I need to ask if the advertising industry are comfortable spending millions of pounds targeting children direct and then saying it's down to mum and dad to stand up to them?"
Parent, quoted in Keep, 2004
16.
Research commissioned by Credos found that advertising and marketing was expressed as a concern by 43 per cent of parents, in the bottom third of a list of 14 issues, and that there is an assumption amongst parents that advertising to children is well—regulated, is fairly mild and reflects society (Advertising Association, 2011). Other Credos research also suggests that further information on regulatory protections and the benefits of advertising (for instance, that it funds many 'free—to—use' services such as social networking sites and commercial television programmes, and that children value the information on new products) tends to mitigate concerns (Credos, 2011).
17.
Our qualitative research with parents also found that, on the whole, provided there are effective provisions in advertising regulation to protect children, as discussed below, the benefits of advertising and marketing to children outweigh perceived risks and harms (Define, 2011).
"We know they have to work by certain standards and rules, [advertising] doesn't bother us too much – there won't be a kid with a cigarette in her hand. So knowing there are those rules and standards makes you worry less about it.
Parent, Review qualitative research
Effectiveness of existing advertising regulation
18.
The system of advertising regulation in the UK is widely seen to be effective. For instance, a review carried out for the European Commission in 2006 found that systems such as that in the UK, with a clear division of work between government and non—government regulators, seem to be highly effective. In its assessment of effectiveness, the review gave a strong rating to the UK system (Hans Bredow lnstitut, 2006). There are explicit provisions in the advertising codes regarding children, enforced by the Advertising Standards Authority and applying to advertising across all media.
19.
The numbers of complaints to the ASA regarding children and advertising are relatively low. Over the course of 2008, 2009 and 2010, 1955 advertisements attracted 8139 complaints about their impact on, or portrayal of, children.To put these numbers into context, the ASA received 80,600 complaints about 42,600 advertisements in total during the same period. Just 4.6 per cent of the advertisements which received complaints overall did so on the grounds of their impact on children (drawing 10 per cent of the complaints) (Advertising Standards Authority, 2011(1)).
Some international approaches to protecting children through advertising regulation
In Australia the issues of commercialisation and sexualisation of children have been the subject of much debate in the last few years and in 2008, following consultation with industry and the public, the Code for Advertising and Marketing Communications for Children was revised, introducing a new code covering sexualisation. Another significant change to the Code was that adverts should not encourage children to pester their parents to buy a particular product – something already included in the UK Advertising Codes. In 2009 a practice guide was published to help advertisers across all media to ensure the protection of children and young people.
Canada is considered to have a highly developed system of codes and standards for responsible advertising to children. Two systems are in operation: one in French—speaking Quebec, where state regulation bans commercial advertising to children under 13 completely, and one covering the other five English—speaking provinces of Canada, where there is a strong system of self—regulation, including pre—clearance of all broadcast adverts aimed at children. However the ban in Quebec on directing commercial advertising to children under 13 years does not apply to signals originating from outside Quebec that are retransmitted by cable TV companies, such as advertising from the English—speaking provinces and the US, and there is limited evidence of the ban’s effectiveness.
In Norway, the government has implemented a number of recommendations designed to reduce the commercial pressure on young people, and to equip children and their parents with the skills to help them understand commercial information and to withstand commercial pressures. As in Quebec, there is a ban on advertising to children under 13 years of age 'by wire or over the air' and advertising is not permitted in schools.
A Consumer Ombudsman aims to initiate discussion with advertisers, media and others, promotes guidelines about appropriate advertising to children and acts as a point of contact for complaints about marketing to children as well as a watchdog for violations of the law.
Norway, too, however is finding it difficult to make national arrangements in a globalised arena. International channels and Norwegian channels broadcast from abroad (including the UK) are able to broadcast adverts to children in Norway. There is also commercial pressure through spin—off products related to popular programmes – for instance in the absence of advertising, some programme content for children now functions like extended commercials or TV character merchandise.
Source: Statham, Mooney and Phoenix, 2011
20.
However, we know that many parents do not make complaints regarding things they do not like even when they feel they have cause to (see Themes 1 and 4). And while there is some evidence that the ASA enjoys a relatively high level of public awareness in comparison with other regulators (Advertising Standards Authority, 2008), recent research suggests that more could be done to increase public understanding of the ASA’s role and of advertising regulation and complaints processes (Advertising Standards Authority, 2011(1)).We welcome the recent public awareness campaign to try to address this (the first for five years by the ASA).Together with the research on complaints cited elsewhere in this report, this suggests that there may be higher levels of concern than are represented by complaints figures.
21.
We are heartened that the industry is already taking a number of steps to ensure advertising and marketing to children is within acceptable standards. We welcome, for example, the introduction of the Children's Ethical Communications Kit website (www.check.uk.com) by the Advertising Association which is designed to help advertisers and marketers understand their responsibilities towards children and how to comply with the CAP codes. We would urge anyone involved in advertising to children to use the website.
22.
We also welcome the recommendations that the Advertising Association has made in its contribution to this Review (Advertising Association, 201 1), in particular the proposal to create an industry panel to consider and take forward any issues relating to advertising and marketing to children that arise from this Review. We were also pleased to learn of the recent appointment of Rachel Childs, a former head teacher of a primary school, and Martin Narey, former Chief Executive of Barnardo's, to the independent ASA Council. They bring their extensive experience of working with children and families to the body that adjudicates on whether the Advertising Codes have been breached.
23.
We do, however, think that there is scope for the advertising industry to go further. As well as ensuring that the ASA interpretation of the CAP codes reflects parental views, a responsible and ethical approach to marketing benefits both business and families and is an essential part of the relationship between commerce and children. Just as we think companies could do more to involve parents and children in responsible product development (Theme 2) and to ensure that parents' voices could be heard more (Theme 4) so we think advertisers and marketers and those who regulate them could be more sensitive to the concerns parents have about advertising. Consequently, we think that more should be done to be sure that advertising regulation is meeting the needs of parents.
24.
As we have seen, children are exposed to an increasing volume of commercial messages (DCSF/DCMS, 2009), not least as they spend more time using the new media. As this area continues to develop at a rapid pace, advertisers and marketers need therefore to take care to continue to act responsibly when communicating to children.
"It's natural. The companies have a responsibility to sell that product so they will sell it at the limit, almost crossing the line."
Parent, Review qualitative research
25.
On the whole, however, parents accept that advertising is necessary for businesses to compete and that it has benefits for consumers, including children.Although parents tend to assume that advertisers will sometimes try to push boundaries, they accept this on the understanding that effective controls are in place.
RECOMMENDATION
7.
Ensuring that the regulation of advertising reflects more closely parents' and children's views. The Advertising Standards Authority (ASA) should conduct research with parents and children on a regular basis in order to gauge their views on the ASA's approach to regulation and on the ASA’s decisions, publishing the results and subsequent action taken in their annual report. ACTION: ASA
Inappropriate advertising
26.
As well as the advertising and marketing messages that children receive for products intended for them, children are also exposed to a far greater volume of advertising and marketing not aimed at them (Advertising Association, 2011). Some parents responding to our Call for Evidence and taking part in our qualitative research were particularly concerned about age-restricted products and services, such as alcohol and gambling, particularly online.There are also concerns about the regulations and rules for restricting advertising of age-restricted products through other media. For example, large numbers of children see alcohol advertising around popular family television programmes and major sports events (Alcohol Concern, 2010).
27.
Online exposure can be exacerbated by children lying about their age in order to register on sites with a minimum age limit, such as a social networking site.This is a practice that is widespread: one third (34 per cent) of 8-12 year-olds have a profile on sites that require users to register as being 13 or over, up from 25 per cent in 2009. Looking specifically at 10-12 year-old internet users, 47 per cent have such a profile, a rise from 35 per cent in 2009 (Ofcom 2011(2)). (See Theme 1 for our recommendation regarding age—restricted material.)
28.
There is extensive guidance, in the Advertising Codes and the Internet Advertising Sales House members code of conduct, for example, and much good practice regarding advertising of age—restricted products online, but the industry acknowledges there is more to be done.We therefore welcome the commitment from the Advertising Association that it will do more to share best practice and explore what more can be done to limit children's exposure to inappropriate product advertising online and that it will continue to liaise with the UK Council for Child Internet Safety (UKCCIS) in developing solutions (Advertising Association, 2011).
'New' marketing techniques
29.
By and large, then, we believe that existing regulatory provisions are in place and working well. However, where regulation has not kept up with developments in marketing communications, we believe that businesses must behave responsibly and not take advantage of those gaps to target children unfairly.
"Technology is moving faster than our ability to regulate it. So we as businesses can't really wait for regulation before we do the right thing."
Business contributor to the Review
"I think internet advertising is really the worst as it completely bypasses any parental supervision."
Parent, Call for Evidence response
30.
While parents say that they are fairly confident in helping their children understand advertising and marketing when they see it in the 'traditional' media (television, radio, billboards, print), some parents taking part in our qualitative research were uneasy about some of the newer marketing techniques used in new digital media, such as advertising by phone or text, the use of 'Like' or 'Favourite' buttons on websites, or internet advertising generally. Awareness of such approaches may be lower, and when they hear about them some parents seem instinctively to consider techniques such as peer—to—peer marketing as not only unsuitable, but also unethical, for use with children (Define, 2011).
Newer advertising and marketing techniques
Peer-to-peer marketing
Peer-to-peer marketing is about incentivising people (through offering a reward of payment or 'free gifts' of goods or services) to market brands to their peers, rather than the advertisers talking directly to people. Marketers use 'peer—to—peer/word—of—mouth' techniques in traditional media as well as online, such as in 'tell a friend' promotions. Marketers also often seek to earn the endorsement of consumers without offering a reward.
Brand ambassadors
A brand ambassador is someone engaged by a brand or agency to promote or present a brand or product to others. This has traditionally involved celebrities or sportspeople acting as the public face of the brand, but a brand ambassador can be anyone being paid to promote a product to others, even for example their friends and family. The advertiser effectively employs the person as they would a traditional advertising medium like TV or Radio.
Advergames
Advergames broadly take the form of an interactive game, featuring a brand, product, good or service.They are hosted both on brands’ own websites and external sites, as well as mobile phone applications and are subject to advertising regulations.
Online behavioural advertising (OBA)
Advertising on the internet is increasingly targeted and one of the ways this can be done is based upon user interests or behaviour. This is achieved when user interests are collected from web browsing activity over a period of time.
Behavioural advertising or interest—based advertising is intended to make display advertising that is more relevant to users’ likely interests. Providers of behavioural advertising create audience segments based on web sites visited over a period of time with a particular browser. These audience segments are then used to provide relevant advertising to users within that segment. For example, a user may visit golf sites often and thus be categorised in the ‘golf enthusiasts’ segment. Some businesses now offer this in real time without the need to create a specific audience segment.
Some of this concern arises because of the nature of marketing through websites, email, text messaging and other digital media. For example, the 'Like' or 'Favourite' buttons on social networking sites, although ostensibly market research tools, can clearly be used as marketing tools but are not classed as such. This adds to the impression of stealth-marketing techniques taking advantage of children's credulity and parents' relative inexperience online. Moreover, as these messages are delivered to the individual, parents are unlikely to know what advertising their children are exposed to at any given time. This combination of the unfamiliar and the unknown can make parents uneasy, as shown by the results of our omnibus survey (see Figure 10).
Figure 10: Parents’ views of marketing and advertising tools
Do you think that any of these marketing and advertising tools should NOT be used when promoting products to children?
Source:TNS Omnibus Survey, 2011 Weighted base: 1199 parents in the UK
32.
The key to helping children to distinguish between advertisements and content is clear and consistent labelling, and there are many examples of good practice, such as the clear separation of 'paid for' and 'non—paid for' search listings on most search engines. And while there is quite a lot of consensus over the age at which children understand television advertising (for example, see the work of Deborah Roedder John, 1999), how children use and understand newer marketing techniques is less certain, particularly as the lines between content and advertising can seem unclear to children, and the types of technique used tend to be processed implicitly and without conscious awareness (Nairn and Fine, 2008)
33.
In March this year, responding to the concerns of UK consumers, industry and policy makers, the ASA's online remit was extended significantly to cover marketing communications on companies’ own websites and in other third party space under their control, such as social networking sites. The CAP Code will be applied in full to this new space.
34.
It is also important that the line between market research (asking children anonymously what they think of a product) and marketing (encouraging them to buy a product) is drawn very firmly in the sand, and the current work of the Market Research Society to clarify this important distinction is to be welcomed (Market Research Society, 2010).
Peer-to-peer marketing and brand ambassadors
35.
Another area of concern for parents is peer-to-peer and brand ambassador marketing, through which young people can receive a payment or payment in kind for promoting a particular product or brand to their friends.
36.
Peer-to-peer marketing might be done online or face to face, and it draws on the long-recognised power of word of mouth to get a marketing message across. Word-of-mouth marketing amplifies and monetises the natural and spontaneous urge we have to tell our friends about the products and services we like.The Word of Mouth Marketing Association (WOMMA) describes it this way:
"Word of mouth is the most effective form of marketing in existence as it combines the newest strategies, tactics, and channels with the most basic human behaviour: people like to talk!"
Word of Mouth Marketing Association
37.
Information about the size of the word-of-mouth industry in the UK is, however, hard to come by: available interim data from a current survey of industry activity indicates that some UK companies have used children under the age of 16 but not the extent of the practice (Advertising Association, 201 1).And parents’ attitudes towards it are mixed. The omnibus survey for this Review showed that more than a quarter of parents (27 per cent) thought peer-to-peer marketing should not be used to promote products to children, while research for the Advertising Association found that while some parents have concerns about the technique, others see some benefits, such as a source of pocket money (Advertising Association, 2011). However, alongside family organisations and consumer groups, many parents in our qualitative research expressed strong concerns about the ethics of paying children, or paying them in kind, to promote products personally to other children.
38.
Whilst aspects of both the brand ambassador and peer—to—peer techniques are regulated, there are currently no regulations regarding the inclusion of children in peer—to—peer marketing campaigns or their employment as brand ambassadors. The WOMMA code stipulates that "A WOMMA member shall not include children under the age of 13 in any of its word of mouth marketing programs or campaigns" (Word of Mouth Marketing Association).
I don't like that peer-to-peer stuff or using my children.
That peer-to-peer thing is extremely worrying, that is morally wrong isn't it...
Parents, Review qualitative research
39.
It has been argued that such techniques can commercialise friendships and disrupt peer relationships for profit (Nairn, 2008).When specific provisions regarding children under the age of 16 are enshrined in the Advertising Codes and with evidence of the significant influence of peer pressure affecting children and parents and of use of 'pester power', we believe that it cannot be right for children to be rewarded for increasing that pressure (see our recommendation below).
Online behavioural advertising
40.
Online behavioural advertising (OBA), a practice that allows brands to deliver adverts that aim to reflect the user's interests, has been at the centre of a privacy debate for the past few years since MEPs, Commissioners and national governments debated wording about 'cookies' (pieces of text sent from web servers and stored on your PC) in the ePrivacy directive adopted in 2009.
41.
The European Advertising Standards Alliance (EASA) Best Practice Recommendation on Online Behavioural Advertising was released on 14 April 2011, and provides for an industry—wide self—regulatory standard for online behavioural advertising. It promotes the identification of OBA advertisements via a uniform European—wide icon, which clicks through to a website, www.youronlinechoices.com, providing information about OBA and a means for consumers to exercise their choice about whether they want to receive OBA advertisements. Consumers that want to complain about an OBA advertisement will be able to do so via the ASA, as for other advertising.
42.
The Best Practice Recommendation will be rolled out over the next twelve months via national industry associations and self—regulatory organisations, such as the ASA, and by mid 2012 it is foreseen that 70 per cent of all member nations will have implemented it.
The Best Practice Recommendation incorporates and complements the Internet Advertising Bureau Europe's 'icon' and consumer web tools.
43.
We welcome this pan—European initiative, which can only improve parents' and children's understanding and awareness of Online BehaviouralAdvertising. However we have some concerns that the provisions relating to children apply only to children under 13, rather than all children under 16, when there have been calls, for instance from Consumer Focus (Pitt, 2010), to define a child as under 16 in all codes and provisions relating to children. There are also concerns that teens might be disproportionately targeted through this technique (Children's Charities' Coalition on Internet Safety, 2010).
44.
Alongside the steps the advertising industry is taking towards ensuring ethical practice in the use of new techniques, the ASA remit is continually reviewed.As noted above, for example, following the receipt of thousands of complaints about online advertising and marketing, from 1 March 2011 the ASA’s remit was extended to cover non—paid—for space online, such as branded content of social networking sites and brands' own websites.
45.
We very much welcome this significant development in the ASA's role, but it is at a very early stage. There will inevitably be grey areas and occasions when it is difficult to distinguish editorial content from a marketing message, and the ASA will need sufficient resources to police this area.This makes it even more necessary for businesses to step up and ensure their marketing complies with the spirit of the regulation as much as the letter, for example by using the Advertising Association's CHECK website. Parents, too, need to identify areas of concern proactively to companies and the ASA.
46.
However, in the longer term, marketing techniques such as word of mouth need to be brought within the ASA’s remit, and the various voluntary codes and sets of guidance currently in development or use should be aligned with the Advertising Codes to give greater clarity and consistency across all aspects of marketing and advertising to children.
RECOMMENDATIONS
8.
Prohibiting the employment of children as brand ambassadors and in peer-to-peer marketing. The Committee ofAdvertising Practice and other advertising and marketing bodies should urgently explore whether, as many parents believe, the advertising self—regulatory codes should prohibit the employment of children under the age of 16 as brand ambassadors or in peer-to-peer marketing – where people are paid, or paid in kind, to promote products, brands or services. ACTION: Committee of Advertising Practice, the Advertising Association and relevant regulators
9.
Defining a child as under the age of 16 in all types of advertising regulation. The ASA should conduct research with parents, children and young people to determine whether the ASA should always define a child as a person under the age of 16, in line with the Committee of Advertising Practice and Broadcast Committee of Advertising Practice codes. ACTION: ASA
Media and commercial literacy
47.
Alongside responsible marketing practices and effective regulation, parents and children should have a sound awareness and understanding of advertising and marketing techniques and regulation.The greater parents' awareness and understanding of marketing communications, the more they will be able to support their children in understanding and navigating the commercial world. Parents are increasingly 'digitally literate', but our qualitative research suggests that aspects of their media and commercial literacy, such as awareness and understanding of some of the newer advertising and marketing techniques, are relatively low. Parents in the qualitative research which informed this Review said they would appreciate more, and more easily accessible, information rather than specific support groups or classes.
48.
While the ASA public awareness campaign and development of the CHECK website for the industry are to be welcomed, there is currently no guidance specifically designed for parents on advertising codes for children.
49.
As the assessment by Professor David Buckingham and colleagues found (DCSF/DCMS, 2009), it is not possible to say unequivocally that children are, in all circumstances, either 'vulnerable' or 'savvy': how children respond to commercial messages depends on the context. The assessment concluded that children's consumer socialisation should be considered in terms of social as well as cognitive capabilities:
"Research on 'consumer socialisation' suggests that children gradually develop a range of skills and knowledge to do with the commercial world that help prepare them for adult life. They are neither the helpless victims imagined by some campaigners nor the autonomous 'media sawy' consumers celebrated by some marketing people. Their engagement with the commercial world is part of their everyday social experience and is very much mediated by other social relationships with family and friends."
DCSF/DCMS, 2009
50.
As young people, parents and teachers become more aware of the ways in which e-commerce proliferates, children are likely to develop increased sophistication in relation to online advertising, as the evidence indicates they have done in relation to more traditional television advertising (Young, 2010).
51.
However, we remain unconvinced that simply improving the media and commercial literacy skills of children provides a sufficient response or protection. Understanding why advertisers often use models who are tall, slim and beautiful, or that some advertisements want us to make an association between a brand and greater happiness or wellbeing, does not make it any more palatable to the child who does not conform to the stereotype of good looks or for whom the cost of a brand keeps it out of reach. Nor does it 'immunise' children from the influence of marketing.
52.
Whilst a range of educational initiatives exist to support children in schools (DCSF/DCMS, 2009; Advertising Association, 2011), there is a need to evaluate further the effectiveness of child media and commercial literacy initiatives both inside and outside schools. There is also a need for an increased focus on improving parents' awareness and understanding of newer marketing techniques and advertising regulation as a whole, enabling them with to support their children better in developing their emotional resilience to commercial pressures.
"If I stand on a pin, the nerves in my foot send a message through my nervous System to ten my brain I am experiencing Pain and to lift my foot. Knowing how the media works is like that. I understand how the System works, but it doesn't stop it hurting."
15 year-old girl in conversation Reg Bailey
CASE STUDY: IMPROVING PARENTS’ MEDIA LITERACY IN ARGENTINA
In partnership with the media industry,Argentina’s Ministry of Education has created a national media education programme.This is designed to increase the ability of children and young people to understand and interpret messages in the media, and to help parents guide their children's relationship with the media.
Booklets for parents have been produced and distributed as inserts in popular newspapers – all funded by industry. ‘TVin the Family’, for instance, answered some frequent questions and concerns that parents have about children and television along with helpful advice to help parents discuss television with their children. 'Internet in the Family' contained tips and recommendations for safer internet use, enabling parents to provide guidance to their children when surfing the internet. Both campaigns were funded by companies in the media and communication industries, and supported by television adverts, radio discussions and an online discussion forum.
Source: Ministry of Education,Argentina
RECOMMENDATIONS
10.
Raising parental awareness of marketing and advertising techniques. Industry and regulators should work together to improve parental awareness of marketing and advertising techniques and of advertising regulation and complaints processes and to promote industry best practice. ACTION:Advertising and marketing industry, with the ASA and the Advertising Association (AA)
11.
Quality assurance for media and commercial literacy resources and education for children. These resources should always include education to help children develop their emotional resilience to the commercial and sexual pressures that today's world places on them. Providers should commission independent evaluation of their provision, not solely measuring take—up but, crucially, to assess its effectiveness. Those bodies with responsibilities for promoting media literacy, including Ofcom and the BBC, should encourage the development of minimum
standards guidance for the content of media and commercial literacy education and resources to children. ACTION: Media and commercial literacy providers, with Ofcom and the BBC
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