Vulnerability is a theme that runs through ad regulation, be it based on membership of a group sharing certain characteristics or on circumstances. CAP and ASA continue their work to meet the strategic goal of prioritising protecting vulnerable people.
Here we look at ads’ potential impact on vulnerable groups.
Gambling
When consumers left an online bingo site to open another tab, the words “Hey! Come Back!” appeared. The ASA considered that a call to action that could encourage people to continue gambling, when they would otherwise have stopped, exploited the susceptibilities of vulnerable people.
Similarly, an ad for a gambling promotion that required punters to place a bet on four, five, six or seven days in a week to qualify for free bets and a share of a promotional pool, run over four weeks, was found to encourage frequent and repetitive participation: gambling behaviour that could lead to financial harm.
Postnatal period
When looking at an ad with a new mum wishing she could lose post-baby weight and another with a breastfeeding “mom” who wanted to be “snatched”, the ASA considered whether the ads suggested that new mothers should prioritise weight loss after birth and exploited insecurities around body image.
The ASA found that the ads irresponsibly encouraged new mothers to prioritise losing weight and included a harmful gender stereotype; therefore, complaints were upheld on this point.
Cost of living
An ad for an equity release plan was considered to play on fears, especially among an older audience who might be struggling financially. It alluded to increased mortgage costs and the cost of living, rather than giving a balanced picture of the benefits and risks of such a complex financial product.
Despite being not-for-profit and member-owned, and providing loans to those experiencing long-term financial hardship, the ASA found a credit union to have encouraged consumers in a vulnerable financial situation to borrow in a way that minimised the decision to take on debt.
Make sure you consider the impact of your ads on vulnerable consumers.
If in doubt, take a look at CAP’s AdviceOnline on Vulnerable people or get in touch with the Copy Advice team.
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