A TV ad for the film The Irishman, was broadcast on ITV at 6 pm on Sunday 17 November 2019 during coverage of the UEFA Euro 2020 Qualifier football match between England and Kosovo. The ad featured a scene of a man holding a gun in each hand. The ad then showed another scene in which a man crawled along the street before being shot by an assailant. The ad was cleared by Clearcast with an ex-kids restriction, which meant it should not be shown in or around programmes made for, specifically targeted, or likely to be of particular appeal to children.
Three complainants, who believed the ad was inappropriate for children to see, challenged whether the ad was scheduled responsibly.
Clearcast said they believed the ad contained scenes of mild, interpersonal violence and that it therefore required an ex-kids restriction. ITV Broadcasting Ltd said that based on Broadcaster’s Audience Research Board (BARB) data, audiences across the UEFA Euro 2020 Qualifiers were adult in composition. They said the programme was neither targeted at nor principally directed towards children, nor of particular appeal to that age group. They said the audience indices for the programme showed that the proportion of child viewers was below the threshold at which they would be considered to appeal particularly to children.
The ASA considered that the ad contained scenes of a violent nature, including the opening clip in which a man held a handgun in each hand, and the scene which followed showing one of the film’s characters crawling on the street before being shot. While each of those scenes was fleeting and lasted no more than a second, we considered the content of the ad was unsuitable for younger children. Consequently, we considered the ex-kids scheduling restriction applied by Clearcast was appropriate, and that the ad should not have been scheduled in or around programmes which were commissioned for, principally directed at or likely to be of particular appeal to children.
We understood that the UEFA Euro 2020 Qualifier between England and Kosovo was not commissioned for, nor principally directed at children, and we therefore assessed the evidence in respect of whether it was likely to be of particular appeal to children.
Broadcasters needed to use the relevant audience data when making scheduling decisions, and where possible, the data should relate to the same or similar programmes that had previously appeared on the same channel during the same part of the day. We assessed the BARB data for the programme, which showed that children made up 8% of the audience of the UEFA Euro 2020 Qualifiers shown throughout 2019. The data also showed that children made up 5.75% of the audience for the match in question. We acknowledged that the ad was broadcast at 6pm on the day in question, which was relatively early in the evening and meant that children were likely to be at home watching television. However, the data showed that children made up only a small proportion of the programme’s audience, and we did not consider the programme itself was likely to be of particular appeal to children.
Consequently, we considered that the ad had not been scheduled for broadcast during a programme that was commissioned for, principally directed at or likely to be of particular appeal to children and therefore concluded that the ad had not been inappropriately scheduled.
We investigated the ad under BCAP Code rules
Advertisements that are suitable for older children but could distress younger children must be sensitively scheduled (see Section 32: Scheduling).
(Children), 32.1 32.1 Broadcasters must exercise responsible judgement on the scheduling of advertisements and operate internal systems capable of identifying and avoiding unsuitable juxtapositions between advertising material and programmes, especially those that could distress or offend viewers or listeners. and 32.3 32.3 Relevant timing restrictions must be applied to advertisements that, through their content, might harm or distress children of particular ages or that are otherwise unsuitable for them. (Scheduling of television and radio advertisements), but did not find it in breach.
No further action necessary.