ASA Adjudication on Norwich Union Insurance Ltd

Ad

A TV ad for Norwich Union car insurance featured three colleagues in a bar discussing their new strategy. The first colleague asked "So when people come to Norwich Union directly for a car insurance quote, we give them our best price and we also offer to tell them our competitors' prices, even if they are cheaper?". The second colleague replied "Yep". The third colleague said "Got it", to which the second colleague asked "Have you?". The third colleague replied "No". A voice-over stated "Come direct to Norwich Union for your car insurance and we'll offer to tell you our competitors' prices even if they are cheaper". On-screen text stated "Prices quoted through E Insurance Services Ltd from participating competitors. Excludes N Ireland. Calls recorded/monitored".

Issue

One viewer, who believed the voice-over in the ad implied that the comparison service offered by Norwich Union was with all of their competitors, challenged whether the on-screen text contradicted that claim by limiting the comparison to participating competitors only.

BCAP TV Code

Response

Norwich Union Insurance Ltd (Norwich Union) said they did not believe the on-screen text contradicted the voice-over. They pointed out that the voice-over did not state that they would tell customers all of their competitors' prices and the on-screen text clearly stated that prices were quoted from participating competitors.

Norwich Union said they were not an aggregator service, but offered their customers the opportunity to compare prices and covers with a range of other insurers so that they could be sure that the Norwich Union cover and price was the best one for them. They explained that they had undertaken customer research in the development of that proposition and that customers had indicated that, while they wanted to be able to check prices and covers, they did not want to be overwhelmed with too many choices. Norwich Union said customers could therefore choose up to three companies to check the prices and cover of at any one time, and that once they had prices for those companies customers could choose to see a further three prices, and so on.

Norwich Union explained that all price and cover information shown in the Full Price Check was provided objectively through E Insurance Services Ltd (E Insurance) with the explicit agreement of the participating companies. Norwich Union explained that some of those companies were themselves panel insurers, which meant that their price was taken from the best price of a range of insurers, and they provided a list of the participating companies. They said they offered their customers three different levels of price check, which were a simple example of a Norwich Union premium versus other companies, a recently shopped quote of a customer with similar details to the customer requesting the quote, or a like for like quote full price check. Norwich Union said their customers could also choose to check their cover details against a wider range of insurers through their Full Cover Check, which compared policy and cover details with over 140 other companies and over 200 products.

Norwich Union said the option to take a price check or cover check was promoted to internet customers on the same screen that gave them their insurance premium quote from Norwich Union. They sent a copy of a screen shot that showed that webpage. They explained that, if after taking that check, a customer wanted to buy their insurance from another provider, they would be directed to an independent cost comparison site. They said the Full Price Check was also available to telephone customers and worked in the same way as described above.

Clearcast said they had approved the ad on the basis that the on-screen texts reference to "participating competitors" clarified the voice-over rather than contradicted it. They also pointed out that the voice-over did not state that Norwich Union would tell customers all of their competitors' prices.

Assessment

Not upheld

The ASA noted Norwich Union's and Clearcast's responses. We also noted that the list of participating companies included both major and smaller insurance providers, and that some of those companies' prices in turn were taken from the best prices offered by a range of other insurers. We considered that customers could therefore check their Norwich Union premium price and policy details against those offered by a wide range of other insurance companies. Because of that, and because the ad did not state that all other competitors' prices would be offered to customers, we concluded that the on-screen text qualified the voice-over and that the ad was not misleading.

We investigated the ad under CAP (Broadcast) TV Advertising Standards Code rules 5.1 (Misleading advertising), 5.2.1 (Claims), 5.2.3 (Qualifications), 5.3.1 (Accurate pricing) and 5.4.2 (Superimposed text) but did not find it in breach.

Action

No further action necessary.

Adjudication of the ASA Council (Broadcast)