ASA Adjudication on Merlin Entertainments (Dungeons) Ltd

Ad

A digital escalator panel poster for the 'Bloody Mary: Killer Queen' attraction at the London Dungeon, which appeared at London Underground stations, showed a portrait of Queen Mary sitting still and passively. Suddenly and quickly she turned to face the viewer and opened her mouth wide in a threatening manner, as if she was screaming. At the same time, her face morphed into that of a zombie-like character, with bloody gashes, white flesh, rotting teeth and red eyes. She then resumed her original passive position and her face returned to normal. On-screen text stated "New for 2010 Bloody Mary: Killer Queen At the London Dungeon ...".

Issue

Four complainants objected that the ad was likely to frighten and distress children, and was therefore inappropriate for display in an untargeted medium. One of the complainants said his eight-year-old child had been frightened by the ad. Another of the complainants said he had seen the ad many times on London Underground escalators and it had visibly shocked and upset several children.

CAP Code

Response

Merlin Entertainments (Merlin) confirmed that the ad contained no audio content. They planned to display it again on the London Underground in the summer holidays and during Halloween.

Merlin said 'Bloody Mary' killed over 300 heretics during her reign but was one of Britain's lesser known villainous figures, overshadowed by her notorious father Henry VIII. The object of the advertising was to show the dark side of her personality and portray her as a villain. They argued that the London Dungeon brought to life the macabre side of London's history and characters, which was reflected in the ad through the use of animation. They believed the ad was obviously historical and was in no way irresponsible or gratuitous.

In order to avoid causing fear and distress, they said they had adhered to London Underground's guidelines in avoiding flames and excessive, dripping or running blood. Merlin said they had also borne in mind the age demographic of London Underground passengers and had tried to ensure that the image used was not too scary. They explained that their agency had developed the advertising campaign in close co-operation with the CAP Copy Advice team, London Underground and CBS Outdoor (an outdoor advertising company with poster sites on the London Underground). CBS Outdoor and London Underground had approved the ad. Merlin believed that by acting in accordance with the guidelines of CBS Outdoor and London Underground, they had acted responsibly towards consumers.

Assessment

Upheld

The ASA noted the ad was untargeted and could therefore be seen by anyone. We considered that the London Underground attracted families and the ad was likely to be seen by young children.

We considered that the morphing image, and the juxtaposition of a calm face with a very scary one, were likely to startle and frighten young children. We noted the switch between the passive and frightening face occurred suddenly and unexpectedly, which could increase the shock value. We also considered that when the face morphed into the scary character, the bloody gashes, white flesh, rotting teeth, red eyes and the threatening expression meant it was not suitable for young children to see.

We were of the view that the ad seemed to be setting out to scare and had overstepped the limit of acceptability in doing so because, although not frightening for adults, the image was likely to be shocking to young children and to cause them fear or distress without good reason. We concluded that the ad was inappropriate for display in an untargeted medium.

The ad breached CAP Code clause 9.1 (Fear and distress).

Action

The ad must not appear again in its current form.

Adjudication of the ASA Council (Non-broadcast)