Summary of Council decision:

Two issues were investigated, one of which was Upheld and one Not upheld.

Ad description

A digital poster for Blackpool Pleasure Beach, seen in September 2021 at the Trafford Centre in Manchester. The ad had an image of a pale face, with yellow eyes, visible cracks on the skin and blood on the teeth and around the mouth. The ad included text that stated “JOURNEY TO HELL FREAK NIGHTS”.


The ASA received 29 complaints.

1. Twenty-six complainants, who believed that the image used in the poster was inappropriate and disturbing for young children, challenged whether the ad was unsuitable for outdoor display.

2. Ten of the complainants also challenged whether the ad was unsuitable for outdoor display because they believed that the image would be disturbing for adults.


1. & 2. Blackpool Pleasure Beach said that the image was displayed at the Trafford Centre, Manchester which received over 35 million visitors a year and the road where it was situated was used by thousands more vehicles as a through road to Manchester. The ad was not targeted at children and due to the location, any children seeing it would have been accompanied by an adult and any viewing of the ad would have been brief.

They explained that the ad was shown at Halloween, recognised within the UK as an annual event and participated in by a wide demographic range, at a time when similar images and themes were displayed in public and was no more likely to cause fear and distress than any other examples.

They believed that the number of complaints received was small for an image that would have been seen by thousands of people from a wide range of demographics. They stated that there had been no intent to cause fear or distress and neither the image nor the wording of the ad offended the general public’s sensitivities.

Perfect Fit Media said they had received three complaints about the ad.

Outsmart said that the ad was not placed near a school and was in keeping with the timing and themes of Halloween. They noted that the image was only mildly scary and was not violent.


1. Upheld

The ASA noted that the face in the ad had a very pale appearance, with cracked skin and yellow eyes, and that its mouth was open, apparently shouting or screaming. There was blood around its mouth and its teeth were jagged, suggesting the character had recently bitten something, and overall it had a threatening expression.

We considered that the image was likely to distress young children, particularly, but not only in combination with the text “JOURNEY TO HELL FREAK NIGHTS”.

For those reasons, we considered that the poster was unsuitable for display in an untargeted medium where it was likely to be seen by young children. We concluded that the ad breached the Code.

The ad breached CAP Code (Edition 12) rules 1.3 (Social Responsibility) and 4.2 (Harm and Offence).

2. Not upheld

We noted the overall impression of the image and recognised that the blood around the mouth and in the teeth of the character may have been disconcerting for some adults. However, we understood that the Halloween theme would be clear to adults and while some might find the image unnerving it was unlikely to cause fear or distress to adults.

On that point, we investigated the ad under CAP Code rules 1.3 (Social Responsibility) and 4.2 (Harm and Offence), but did not find it in breach.


The ad must not appear again in its current form. We told Blackpool Pleasure Beach Ltd to ensure that ads which were likely to cause fear or distress for young children did not appear where they were likely to see it.

CAP Code (Edition 12)

1.3     4.2    

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