ASA Adjudication on Procter & Gamble (Health & Beauty Care) Ltd

Ad

A magazine ad for the Olay Definity eye illuminator featured an image of the model Twiggy. A testimonial adjacent to her stated "Olay is my secret to brighter-looking eyes!. Further text stated "Because younger-looking eyes never go out of fashion. Olay Definity eye illuminator. Reduces the look of wrinkles and dark circles for brighter, younger-looking eyes."

Background

We received identical complaints about a magazine ad for the Olay Definity eye illuminator from over 700 members of the public who complained via a website campaign. Their complaints were forwarded to the ASA by Jo Swinson MP. We also received a complaint from a member of the public who contacted us directly. All the complainants challenged whether the ad was misleading because they believed the image of Twiggy had been digitally re-touched; the people who complained as part of Jo Swinson's campaign also complained that the ad was socially irresponsible.

Issue

1. Many complainants, who had forwarded their complaints to Jo Swinson MP as part of a website campaign, objected that the ad was misleading and socially irresponsible. They believed the image of Twiggy had been digitally retouched and the use of post-production techniques could have a negative impact on peoples perceptions of their own body image.

2. One complainant, who contacted the ASA directly, objected that the ad was misleading, because it implied that Twiggys appearance in the ad was achieved solely through the use of Olay Definity rather than with the assistance of photographic post-production.

CAP Code (Edition 11)

Response

1. & 2. Procter and Gamble Ltd (P&G) said that Twiggy was a beautiful woman who had been chosen to appear in a number of high profile advertising campaigns, including theirs. They said there would always be differences between uncomplimentary paparazzi shots and professional beauty photographs and that celebrities were always at risk of less than flattering shots of them "off duty" being taken and used in the media. They believed an article in a national newspaper, which compared such an "off duty" shot of Twiggy with one in the Olay campaign, may have prompted complaints about the ad.

P&G said that, in the photo shoot for the Olay Definity campaign, Twiggy's hair and make-up were done by professional hair and make-up artists. They said it was entirely routine practice to choose beautiful women as models and use cosmetics, hair styling and lighting to show them at their best. They said it was also routine practice to use post-production techniques to correct for lighting and other minor photographic deficiencies before publishing the final shots as part of an advertising campaign.

P&G said that, in July 2009, when the ad was questioned in the media, they reviewed the post-production used in the ad and concluded there had been some minor retouching around Twiggy's eyes which was inconsistent with their own policies. They said they withdrew that ad and replaced it with one in which there had been no post-production work in the eye area.

P&G said the ad for Definity eye illuminator had been placed in magazines read by more mature women to whom Twiggy would be likely to appeal. They said they did not accept that there was any likelihood of that ad, regardless of any post-production retouching, having a negative impact on people's perceptions of their own body image, or being in any way socially irresponsible.

Assessment

1. & 2. Upheld

The ASA noted the original ad seen by the complainants had been withdrawn and replaced with one that did not have re-touching around Twiggys eyes. We acknowledged that advertisers were keen to present their products in their most positive light using techniques such as post-production enhancement and the re-touching of images. However, we considered that the post-production re-touching of this ad, specifically in the eye area, could give consumers a misleading impression of the effect the product could achieve. We considered that the combination of references to "younger-looking eyes", including the claim "Reduces the look of wrinkles and dark circles for brighter, young-looking eyes", and post-production re-touching of Twiggys image around the eye area was likely to mislead.

Notwithstanding that, we considered that consumers were likely to expect a degree of glamour in images for beauty products and would therefore expect Twiggy to have been professionally styled and made-up for the photo shoot, and to have been photographed professionally.  We also noted the ad appeared in a magazine that targeted mature women and considered that readers of Good Housekeeping magazine and the Sunday Times Style Supplement would understand that the ad set out to associate the well-known mature female model with a brand, and would not infer that Twiggys appearance in the ad was achieved solely through the use of Olay Definity.  We concluded that, in the context of an ad that featured a mature model likely to appeal to women of an older age group, the image was unlikely to have a negative impact on perceptions of body image among the target audience and was not socially irresponsible.

The ad breached CAP Code clause 7.1 (Misleading advertising).

We also investigated the ad under 2.2 (Social responsibility) but did not find it in breach.

Action

Because this version of the ad has now been withdrawn, no further action is required.

Adjudication of the ASA Council (Broadcast)