ASA Adjudication on HSBC Bank plc

Ad

A direct mailing from HSBC contained a fake till receipt only. Text on the front of the envelope stated "What's the price of a happy future?". The top of the receipt stated "Super.corp Milton Keynes, Sky Centre Central Greater London". The receipt contained an itemised list of 'futuristic' groceries and household products including "Domestic water credit 1 wk prepay £300.00 ... Negative cal chocs £10.64 ... Bananapples £12.24 ... Memory upgrade, personal £1,000.00 ... Ramsgate Rioja 2010 £100.00", etc. The receipt totalled £2,816.64 and was dated 29/11/2027.

The reverse of the receipt contained text that stated "The future's mindblowing. So is the cost. Some things never change. Whatever innovations tomorrow brings, you'll still need to put food on the table. And more than likely, you'll still have good reason to frown at the cost of your weekly shop. At HSBC, we'd like to do whatever we can to ensure you're ready for the future, so you can afford all the exciting developments that come with it. That's why we're offering you an Individual Review at your nearest HSBC or over the phone ...".

Issue

Ten complainants objected that the ad was distressing and irresponsible because they initially believed the till receipt was real and they were victims of identity theft.

CAP Code (Edition 11)

Response

HSBC said the till receipt direct mailing campaign was a follow-up activity and was part of a larger direct mail campaign targeted at customers aged 45 to 64 years old. They said the initial mailing contained a copy of the Times newspaper featuring news items focusing on how the world might look in 2027. They said that, two weeks later, the till receipt, also dated 2027, was mailed as a follow-up to reinforce the idea of the potential high cost of weekly groceries in twenty years time. They said half the recipients of the first mailing received the till receipt mailing and the intention was to create resonance between the two pieces.

HSBC outlined their creative rationale for the advertising. They believed the till receipt was in keeping with the light-hearted thought-provoking vision of the future conveyed in the first mailing. They said both the goods and the prices listed on the receipt were a tongue-in-cheek means of conveying the idea that the future was difficult to predict, especially an individual's ever changing financial circumstances. They said the copy on the reverse of the receipt highlighted the issue of finance in the future and the importance of being prepared for the unforeseen, and offered customers the chance to talk to a branch counsellor.

HSBC said that they took their responsibilities towards customers very seriously and withdrew the advertising as soon as they realised it had been misinterpreted. They said they had written to all customers who contacted HSBC directly and apologised for any distress the till receipt mailing may have caused. They said it was not their intention, nor in their interest, to cause fear or distress from any marketing communication.

HSBC said they had tried to ensure the receipt was not interpreted as a bill by clearly dating it 2027, by not including any of the customers personal details on the receipt and showing a list of imaginary items. On the reverse was information about booking a HSBC Bank Individual Review. They believed that the ad was clearly presented as a marketing communication because the outer envelope was red and a different colour and size to envelopes used for HSBC postal statements. They pointed out that the envelope contained the line "What's the price of a happy future?" which they believed clearly denoted that the mailing was a marketing communication. They said the reverse of the till receipt contained a clear marketing message and a call to action.

HSBC confirmed that they would not repeat the till receipt mailing.

Assessment

Not upheld

The ASA understood that the till receipt direct mailing was sent to HSBC customers only and was intended to create resonance with an earlier mailing sent to the same customers. We noted that the front of the envelope contained the text "What's the price of a happy future?" and showed the HSBC logo and the reverse of the envelope contained a HSBC return address. We accepted that the envelope was clearly identifiable as a marketing communication from HSBC.

We acknowledged that the till receipt contained no personal details of the customer and was clearly dated "29/11/2027" in bold text. We noted that the receipt contained fictional items such as "Ramsgate Rioja", "No-hangover cider", and "courgarrots" and considered that those were tongue-in-cheek and significantly detached from reality. We noted that the reverse of the till receipt was clearly branded with the HSBC logo and contained a marketing message which offered HSBC customer's the chance to book an individual review with a branch counsellor. We concluded that the direct mailing was clearly identifiable as a marketing communication.

We acknowledged that some recipients initially believed the receipt was genuine and that they had become victims of identity theft, which had caused them some distress. However, because the receipt was fictitious and the envelope was clearly identifiable as a HSBC marketing communication, we concluded the mailing was not irresponsible and was unlikely to cause undue fear and distress.

We investigated the ad under CAP Code clauses 2.2 (Responsible advertising), 9.1 (Fear and distress), and 22.1 (Recognising marketing communications and identifying marketers) but did not find it in breach.

Action

No further action required.

Adjudication of the ASA Council (Non-broadcast)