ASA Adjudication on Jack Wills Ltd

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A catalogue, for Jack Wills, advertising male and female clothing, included a double-page spread of black and white photographs showing a young man and woman on a beach. On the left-hand side of the page was a photograph of the young woman who was naked from the waist up. She was covering her breasts with her right arm while the young man filmed her with a hand-held video camera. The right-hand side of the page showed five smaller pictures of the young woman in similar poses, with her arm across her breasts. In all the photographs, she was smiling at the camera.

Issue

The complainant thought that the images were sexualised and therefore inappropriate for a clothing range which she believed targeted teenagers.

CAP Code (Edition 11)

Response

Jack Wills said their brand targeted men and women of student age. They explained that the images they used to promote it were designed to reflect an aspirational lifestyle where individuals were happy, healthy and laid-back.

Jack Wills said they appreciated that this type of lifestyle could appeal to people younger than their target audience and those younger readers could have been exposed to the catalogue by older siblings. They explained that recipients would either have signed up to receive the catalogue in one of their stores or requested it from their website. Jack Wills pointed out, however, that parents could request the removal of any family member's name from the mailing list. They told the ASA that the catalogue had a UK circulation of approximately 40,000.

Jack Wills explained that the theme of the catalogue, in general, was the long summer breaks enjoyed by students and they expressed regret that the images had caused offence. They stressed that the images were not intended to convey any salacious or sinister meaning. Rather, Jack Wills said they believed the photographs depicted a playful and light-hearted scene where a young man had caught his female friend on camera while she was changing in the sand dunes; she was play-acting that she was shocked to have been caught topless and was shooing her friend away.

Jack Wills pointed out that the model had been styled wearing full-length trousers so as not to appear too underdressed and said she was not revealing any more flesh than if she had been wearing a bikini. They assured us that they had not set out to sexualise the content of their catalogue and said they believed the images were relevant to their target market and in good taste.

Assessment

Not upheld

The ASA noted Jack Wills' comments. We noted the young woman was topless but that her breasts were covered; we therefore considered that the images were not overtly sexual in content. We also noted the model appeared to be having fun and did not seem to be striking any particularly provocative poses. We acknowledged that the target audience of the Jack Wills brand were young adults who were likely to identify with the carefree overtones of the images and that recipients of the catalogue had actively requested to receive it. Although we understood that some younger teenagers might view the catalogue, or sign up to receive it, we concluded that the images were not so provocative as to present a risk to teenagers or be unsuitable for the target audience.

We investigated the catalogue under CAP Code clauses 2.2 (Responsibility) and 47.1 (Children) but did not find it in breach.

Action

No further action necessary.

Adjudication of the ASA Council (Non-broadcast)