A poster, seen during June and July 2023, featured an image of the top half of model and influencer Eliza Rose Watson posing in a bra top. Text stated “@ ELIZAROSEWATSON” with the logos of the OnlyFans and Instagram social media platforms.
The ASA received 30 complaints:
1. All the complainants, who understood that OnlyFans was an internet content subscription service which featured sexual adult content, challenged whether the ad was inappropriate for display in an untargeted medium where children could see it.
2. Many of the complainants, who believed the ad was overly sexualised and objectified women, also challenged whether the ad was offensive, harmful and irresponsible.
1. & 2. Eliza Rose Watson said the ad adhered to advertising guidelines and reflected trends in leading brands. The development process took over a month, during which she ensured the ad was tailored to avoid offensiveness to mature viewers and intrigue to the younger generation. The image selected was evaluated by a diverse group, beyond those in the glamour industry. It was deemed to be non-suggestive, not harmful and less provocative than mainstream lingerie or perfume brand advertisements. Ms Watson provided examples of ads for clothing and condom brands which she believed were shown in busier areas of London. She said that, in her experience of social media channels, radio and TV discussions, a significant majority of consumers did not find the ad offensive.
The ad deliberately omitted any explicit website link or call to action, which was intended to veil the OnlyFans platform from those who may not be aware of it or wished to engage with it. The use of the OnlyFans logo was consistent with its appearance in mainstream media. Ms Watson provided images of a racing car and boxer showing the OnlyFans logo being featured on their clothing and car.
Ms Watson said in selecting the sites for placing the ad, consideration was given to child safety. There was no intention to place the ads in the vicinity of schools. The content of the ad was adult-centric and did not include anything appealing to minors such as bright colours, engaging slogans, fun factors or QR codes. The data from her social media channels confirmed an audience aged 25-44 years. She said the OnlyFans website had stringent restrictions in place for users under 18.
Ms Watson said the ad was only showing her likeness to members of the public. There was no attempt on her part to appear any more or less than herself in the image. She was not presenting a ‘stereotypical’ image of herself in the ad, it was merely who she was as a person.
Amplify Outdoor, the media site owner, said they were approached by an agency to display the ad throughout London. After seeing the ad, they provided the agency with a poster site list with addresses and coordinates for them to select the locations. When discussing the initial site list, they and the agency removed the sites close to schools before submitting the updated list with recommendations to Ms Watson. They said none of the posters were displayed within 100 metres of a school, with the closest being 450 metres from the nearest school.
They believed the ad was suitable because it had no mention of sexual services or pornographic content. It was not degrading to women, indecent or of a sexual nature, and was similar to a shampoo, gym wear or lingerie ad. The use of the image was directly relevant to the advertiser’s brand and business and did not employ sexual appeal in a manner which was exploitative of women. They believed the overall content of the ad was consistent with many other outdoor campaigns using an image and icons popular with social media sites. They said children in general did not know about OnlyFans. The site was a locked site and minors were prevented from accessing content.
Amplify Outdoor said they never intended to cause offense by placing the ads but simply wished to provide a voice to a legitimate business that wanted to use their network. They believed most of the negative comments came with the increased media attention at the beginning of July. They said they had received one complaint direct.
1. & 2 Not upheld
The ad featured an image of Eliza Rose Watson wearing a bra top which showed her cleavage. Her hair was tousled over her face and her mouth was slightly open. The ASA considered that although her clothing was revealing, the image did not feature any nudity, and the pose adopted by Ms Watson was no more than mildly sexual.
The ad also featured the Instagram and OnlyFans logos. We understood that the OnlyFans platform featured various kinds of creative content posted by subscribers to its service, including adult sexual content. Therefore, the image of Ms Watson would be particularly relevant to the OnlyFans service, and in keeping with some of its usual content. Both the Instagram and OnlyFans logos were the standard company logos which people who were familiar with those platforms would be familiar with seeing. Although the OnlyFans website featured explicit adult content, the ad did not feature any explicit imagery. The ad promoted Ms Watson and her business on online platforms. It did not contain anything which indicated an exploitative or degrading scenario or tone. While we acknowledged that the image of Ms Watson and reference to OnlyFans might be distasteful to some, we considered that because the ad was not overtly sexual and did not objectify women, we therefore concluded it was unlikely to cause serious or widespread offence.
The ad was shown on several posters throughout London, which was an untargeted medium, and was therefore likely to be seen by a large number of people, including children. However, because we considered the ad was not overtly sexual and did not objectify women, we therefore concluded the ad was unlikely to cause serious or widespread offence and had not been placed irresponsibly.
We investigated the ad under CAP Code (Edition 12) rules 1.3 (Social responsibility), 4.1 and 4.9 (Harm and offence), but did not find it in breach.
No further action necessary.