Note: This advice is given by the CAP Executive about non-broadcast advertising. It does not constitute legal advice. It does not bind CAP, CAP advisory panels or the Advertising Standards Authority.

Some people with mental health conditions may find certain imagery highly ‘triggering’, which means it provokes an emotional reaction that can cause distress or harm, including panic attacks or flashbacks. While the type of image that can cause this reaction varies widely and, depending on the individual, may seem to be innocuous, there are some types of imagery that are more likely to cause distress or harm to people in vulnerable circumstances, such as those affected by phobias and serious mental health conditions.

Imagery relating to self-harm, trauma, suicide or excessive thinness are all more likely than other images to be considered unacceptable unless there is strong justification for their inclusion (such as an awareness campaign).

However, although other imagery may be problematic for some people, it may not breach the Codes. ASA investigations in this area have primarily been in relation to phobias, but this position is likely to apply more broadly and cover other conditions that may be provoked by certain images or themes. The ASA has received many complaints over the years about ads that have upset people because of their phobias. While phobias are very real and individual to people who suffer from them, almost any theme or imagery in an ad has the potential to trigger someone’s phobia. What one person may find harmful and distressing, another person may not.

Touching on a theme that is uncomfortable for a section of the audience with a particular sensitivity is almost inevitable, so the fact that an ad contains something that may be distressing for someone (such as spiders) is not in itself a breach of the Codes. What is more important is the copy as a whole and whether it is likely to cause offencefear or distress - even to those who don’t suffer from a phobia and who wouldn’t ordinarily have an adverse reaction to an image in and of itself. As always, context is key. The ASA isn’t likely to stop a horror movie featuring their iconic clown in their ads; provided that it isn’t menacing, overtly threatening or suggestive of danger then it’s likely to be acceptable, even in an untargeted medium.

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