ASA Adjudication on Shop Direct Financial Services Ltd

Ad

A direct mailing, for the Direct Plus Account, stated "WITH A DIRECT PLUS ACCOUNT YOU CAN AFFORD TO LOOK GORGEOUS Dear X Need a new outfit fast? Listen up girls. Hot dates won't wait 'til payday. By the time you can afford that sexy new outfit Mr Right (or Mr Right Now!) could be long gone. That's where we come in. Think of us as your fairy godsister. All you have to do is say the three magic words. Direct Plus Account. And before you know it you'll be decked out and partying like there's no tomorrow. No cash required. Strain your wardrobe, not your wallet! So here's the deal. Direct Plus Account is a totally non-scary credit account that lets you order the things you want from additions with no cash to pay upfront ...". The mailing featured a series of cartoon scenes of a young woman with accompanying captions. One scene was captioned "Now she's got a Direct Plus Account there's no stopping her!" A second scene showed the woman in a pair of high heeled shoes on a dance floor; the caption stated "ON A GIRLS NIGHT OUT I'd kill for those shoes Wouldn't we ALL!!" A third scene showed the woman and a man at home watching TV; the caption stated "BACK AT THE FLAT 40" LCD TV nice one! how does she do it? ...". A fourth scene was captioned "AT THE OFFICE... not ANOTHER new outfit. How can she afford it??? If only they knew her secret". Text continued "Now it's your turn to get what you want Why let money come between you and a good time? Direct Plus Account* lets you spread the cost of your new designer jeans so you've got more cash to spend having fun ... Set up a Direct Plus Account today. It's a girl's best friend! ...". Text on the first and final page of the mailing stated "typical 29.8% APR variable".

Issue

The complainant thought the ad was irresponsible, because it encouraged young women to spend excessively on a credit account and get into debt.

CAP Code (Edition 11)

Response

Shop Direct Financial Services (SDFS) said the mailing was sent to approximately 75,000 Additions Direct customers aged over 18 years.  They explained that a high proportion of Additions Direct customers were in their twenties and thirties, which was the youngest age profile of all the brands in the Littlewoods Shop Direct Group.  The animated story format was intended to convey the benefits of the credit account to the target audience in a fun, informative way.  SDFS believed the ad was compliant with all relevant consumer protection legislation.

SDFS argued that the animated story format clearly involved an element of fantasy and would not be seen by recipients of the mailing as a serious lifestyle endorsement.  They nevertheless pointed out that the ad contained details of the interest rate and the choice between making minimum payments or taking three months interest opt-out which, they said, constituted all the technical information customers needed to understand how the credit account operated.

SDFS explained that any customers who applied for a credit account in response to the ad would be credit scored to assess their ability to pay and, if accepted, would be offered a credit limit based on their personal financial circumstances.  They felt the ad did not encourage recipients to spend excessively and beyond their means and was not prepared irresponsibly.

Assessment

Upheld

The ASA considered the ad portrayed a young woman living a glamorous lifestyle on credit, buying whatever she wanted whenever she wanted and being the envy of her friends.  We noted it contained phrases such as "Hot dates wont wait til payday.  By the time you can afford that sexy new outfit Mr Right ... could be long gone.  Thats where we come in", "before you know it youll be decked out and partying like theres no tomorrow" and "Now its your turn to get what you want Why let money come between you and a good time?"  Although successful applicants would be given a credit limit, we nevertheless considered that the ad was designed to appeal particularly to young women and was likely to be seen as encouraging care-free, impulsive spending on credit; we were not convinced that it would be seen as depicting only fantasy spending.  Notwithstanding the inclusion of the typical APR, we considered that, by portraying an aspirational lifestyle purchased impulsively on credit, the ad was likely to be seen as encouraging young women to spend excessively on a credit account and, as such, was irresponsible.

The ad breached CAP Code clause 2.2 (Responsible advertising).

Action

We told SDFS not to repeat the approach and advised them to contact the CAP Copy Advice team before producing future similar material.

Adjudication of the ASA Council (Non-broadcast)