Ad description
A poster ad and a press ad for KFC:
a. The poster, seen at bus stops and other locations during September 2019, featured the phrase “WHAT THE CLUCK?! £1.99 FILL UP LUNCH” alongside an image of food items on a menu.
b. The press ads seen in the Metro and the Sun also during September 2019 were the same as the poster except one featured the elongated word “cluuuuuck”.
Issue
1. All of the complainants, who believed the word “cluck” had been substituted in place of an expletive, challenged whether ads (a) and (b) were offensive.
2. Many of the complainants also challenged whether ads (a) and (b) were appropriate for display where they could be seen by children.
Response
1. & 2. Kentucky Fried Chicken (Great Britain) Ltd t/a KFC said they did not agree that the claim included a word which was a substitute for an expletive. They said the phrase “what the cluck?” represented the customers’ response to a great value KFC deal. They said the word “cluck” was used as an onomatopoeic reference to the noise of a chicken, which was in context and wholly relevant to the deal, the product featured and the brand.
KFC said ad (a) was a continuation of their value campaign which had launched on TV and radio and featured the same phrase and real sound effects of a chicken. The use of the word “cluck” was a tool to visually represent the sound effects of a chicken. KFC said the ad did not use the word “fuck” and they did not believe there was any ambiguity in the typeface or arrangement of the wording in the ad which could have allowed for it to be interpreted as an expletive. They said they believed it was unlikely that children would make any connection between “cluck” and “fuck” given the clear typeface they used and would more likely connect it with the sound made by a chicken. They added that they chose locations for their posters in order to maximise coverage to adults over 16 years of age, and that in line with their self-imposed regulations no ad was displayed within 200 metres of schools. Regarding ad (b), KFC said the elongated spelling of the word “cluck” did not create any ambiguity that could allow for the word to be either misread or misinterpreted as an expletive. They said all newspapers which featured the ad had adult target audiences and readership and in all instances the ad appeared outside of the first 20% of the publication making the likelihood of children seeing the ad even lower.
J C Decaux, which owned the poster site, said their campaign management team did not refer the ad for internal approval; because it did not contain a swear word and would be 200 metres away from schools, they believed the rhyme would be acceptable and appropriate. They apologised for the oversight and said they had advised their team that in future any allusion to a swear word should be escalated for approval. The Metro said the newspaper was not published for, or targeted at, children but was for an adult audience aged 18‒44 who lived in metropolitan areas. They also added that this ad was not published on the front page of the newspaper. The Sun said they were not aware of any complaints in relation to the ad, and therefore did not have any evidence to suggest that its readers found the press advert offensive.
Assessment
1. & 2. Upheld
The ASA understood that the use of the word “cluck” was a reference to the sound a chicken made and that that was relevant to the product being advertised. We also acknowledged that the ad did not contain the expletive “fuck”. We recognised that there were several variations of the “what the…” expression, all commonly used to denote surprise or outrage, and not all of which finished with an expletive. The chicken sound effect used to complete the expression in the radio and TV ads in the campaign did not therefore directly substitute for an expletive. However, the written word “cluck” was used in the poster and press ads and we considered people would interpret that as alluding specifically to the expression, “what the fuck”. We did not consider that this connection would be removed because an elongated spelling of the word “cluck” was used in ad (b).
We considered that fuck was a word so likely to offend that it should not generally be used or alluded to in advertising, regardless of whether the ad was featured in a newspaper which had an adult target audience. We also considered it likely that parents may want their children to avoid the word, or obvious allusions to it. The poster was likely to be seen by people of all ages and while we recognised that the press ads would have a primarily adult audience, they could still be seen by children. For those reasons we concluded that the allusion to the word “fuck” in ads with a general adult audience was likely to cause serious and widespread offence, and that it was irresponsible for them to appear where children could see them.
The ad breached CAP Code (Edition 12) rules 1.3 (Responsible advertising) and 4.1 (H
Action
The ad must not appear again in its current form. We told Kentucky Fried Chicken (Great Britain) Ltd t/a KFC to avoid in future alluding to expletives that were so likely to offend.
