Ad description

A website for UpFront Reviews,, seen on 7 July 2017, stated on a page titled “Accommodation Reviews” that the “Average rating” of properties included in the “Amberley House Cottage Holidays Group” portfolio was “4.6 OUT OF 5”. An individual property listing for “Hall House”, a property in Amberley House Cottage Holidays’ portfolio, was not shown.


The complainant, who had submitted a negative review for “Hall House” and believed the property had been removed from the website before the review was published to help maintain a high overall score, challenged whether the overall score “4.6 OUT OF 5” was misleading.


Amberley House Cottage Holidays said their overall rating of 4.6 out of 5 was based on the scores from all their reviews, including properties such as Hall House which had been removed. They stated the reviews for this particular property had been removed as the owner had “opted out” of UpFront Reviews. However, the historic reviews from all properties which had been removed still contributed towards the overall rating of their group portfolio, including the complaint’s review of Hall House. Additionally, they said they allowed any genuine review relating to their properties to be published. They highlighted examples of three published reviews for another property in their portfolio with ratings below 3 out of 5.

Amberley House Cottage Holidays said that there was also a procedure in which requests to remove reviews could be submitted to Upfront Reviews, and that this process was closely monitored by Upfront Reviews, with strict criteria that must be met to remove a review.

Supercontrol Ltd t/a Upfront Reviews also stated that in this instance the client had opted out of Hall House as per the usual process and therefore the reviews for the property were removed. However, the property’s ratings still counted towards the overall score of the agency. They said their review service was entirely optional for clients, therefore clients could “opt out” of the service for individual properties or a group of properties at any time, and there were no requirements or criteria to meet in order to opt out of a property. They said if a client opted out of an individual property from a group portfolio, the property’s historical scores still counted towards the client agency’s overall score, although the property’s reviews would no longer be displayed.

UpFront Reviews provided evidence to show that the scores from the historic reviews of Hall House, and four other properties which had also been hidden, were counted in the calculation of the overall average score for the Amberley House Cottage Holidays group.


Not upheld

The ASA considered that consumers would be likely to expect overall average review ratings for rental properties to be comprised of all the reviews received, both positive and negative, but that it was reasonable to remove reviews which were independently assessed as not to be genuine or truthful.

We understood that Hall House had been removed from the group portfolio on the Upfront Reviews website as the owner had opted out of the review service, and there were also no ratings or independent reviews for the property on the Amberley House Cottage Holidays website. We also understood that in order to “opt out” of Upfront Reviews owners had to forego of all the reviews for a particular property, rather than an individual review only, and that the scores from opted out properties still counted towards overall group ratings for agencies such as Amberley House Cottage Holidays. Upfront Reviews and Amberley House Cottage Holidays had provided evidence which demonstrated that the scoring from the reviews of Hall House, including that of the complainant’s review, had contributed towards the overall score of “4.6” out of 5 of the Amberley House Cottage Holidays group portfolio, and therefore the overall score “4.6 OUT OF 5” had been substantiated.

We therefore concluded that the overall review rating claim for the group portfolio was not likely to mislead.

We investigated the ad under CAP Code (Edition 12) rules  3.1 3.1 Marketing communications must not materially mislead or be likely to do so.    3.3 3.3 Marketing communications must not mislead the consumer by omitting material information. They must not mislead by hiding material information or presenting it in an unclear, unintelligible, ambiguous or untimely manner.
Material information is information that the consumer needs to make informed decisions in relation to a product. Whether the omission or presentation of material information is likely to mislead the consumer depends on the context, the  medium and, if the medium of the marketing communication is constrained by time or space, the measures that the marketer takes to make that information available to the consumer by other means.
 (Misleading advertising) and  3.7 3.7 Before distributing or submitting a marketing communication for publication, marketers must hold documentary evidence to prove claims that consumers are likely to regard as objective and that are capable of objective substantiation. The ASA may regard claims as misleading in the absence of adequate substantiation.  (Substantiation), but did not find it in breach.


No further action required.

CAP Code (Edition 12)

3.1     3.3     3.7    

More on