ASA Adjudication on Urban Crowd Ltd
Urban Crowd Ltd t/a
32 Abington Square
1 February 2012
Number of complaints:
The ASA originally received four complaints about Urban Tiger’s poster ad in August 2011. The ASA Council considered the ad in early September, and concluded that the ad was unlikely to cause serious or widespread offence, would not be seen as objectifying women and would not be likely to cause harm to children.
On 7 October 2011, the ASA issued new guidance on sexual imagery in outdoor advertising. That followed the publication of the independent report 'Letting Children be Children' by the Department for Education after a review by Reg Bailey, Chief Executive of the Mother’s Union, into the commercialisation and sexualisation of childhood, and our own research into the views of parents and children about irresponsible advertising. The ASA’s guidance informed the advertising industry that we would consider complaints about sexual imagery in outdoor advertising in light of the new evidence we had received about the public’s views. In accordance with that guidance, we are considering Urban Tiger’s ad again in light of the new complaint we have received.
A poster, for a lap dancing club, viewed on 14 October 2011, was headed “URBAN TIGER GENTLEMAN’S CLUB NORTHAMPTON’S FINEST LAPDANCING CLUB - Luxurious table dancing venue - Stag Parties & special events - Corporate entertainment”. To the right-hand side of the poster was an image of a woman wearing a sheer white dress cut to the waist. Her hair covered her cleavage. She sat side-on, facing to the left, and leant back slightly on her left arm. Her right arm rested on her left knee. Her legs were exposed from the thigh down.
The complainant challenged whether, given its content and the nature of the advertised venue, the ad was unsuitable for display close to a primary school where it could be seen by children.
CAP Code (Edition 12)
Urban Crowd said that they believed the ASA might have received a complaint about the ad not because of its content, but because the complainant might object to the type of business it was advertising. They said they were very conscious of objections to the nature of their business and as a result were sensitive about the content of their advertising, and it was their policy to avoid using images which were too revealing or controversial. They said they believed the ad in question followed that policy; it advertised their business but the model was wearing a significant amount of clothing and was not in a pose that could be considered sexual. They said poster ads advertising products such as underwear and deodorant often featured models wearing less clothing. They added that they also believed there was nothing in the text of the ad which was offensive.
Urban Crowd said they had no desire to offend people and so had a policy whereby they tried to display their poster ads near business and industrial areas or on major roads, avoiding residential areas and schools. They said the ad in question was on a major road which was two streets, and approximately 400 metres away, from the entrance to the school the complainant had mentioned. They thought the location was not one where all the children would see it as they arrived or departed from school.
Clear Channel, who owned the poster site, said they had placed a restriction on the ad so that it would not be displayed within 100 metres of schools. They said that the ASA had reviewed the ad in September 2011 after receiving complaints, but had concluded that no further action was warranted. They said that for those reasons they considered the ad was in compliance with the newly established rules following the Bailey Report into the commercialisation and sexualisation of childhood.
The ASA acknowledged that in the context of an ad for a lap dancing club, it was likely that most images of women would be interpreted to be at least mildly sexual because of the nature of the service advertised. However, we noted the Code stated that the fact that a product was offensive to some people was not grounds for finding a marketing communication in breach of the Code. We therefore considered the ad on the basis of the image, the text and the ad’s overall impression.
We considered that the overall impression of the ad was that it was only mildly sexual. We noted the text that described the club used non-sexual language and considered that the woman’s stance was not sexually suggestive. We noted that although the woman’s dress was cut to the waist, her hair completely covered her cleavage and considered that although she was leaning back she was not arching her back in a sexually provocative way. For those reasons, we considered the ad was only mildly sexual and was unlikely to cause serious or widespread offence or be seen as socially irresponsible. However, we welcomed the policy Urban Tiger had in place with regard to the placement of their ads, and Clear Channel’s decision to impose a restriction to ensure that the ad would not be displayed within 100 metres of a school.
We investigated the ad under CAP Code rules 1.3 (Irresponsible advertising) and 4.1 (Harm and offence), but did not find it in breach.
No further action necessary.