A poster for PrimEvil, a horror-themed Halloween event at Norfolk Dinosaur Park, seen in Norwich in September 2023, featured text that stated “SCREAMING WON’T HELP […] Welcome to the hell we now call home” and an image of a person with a severe head wound whose flesh, nose and lips appeared to have rotted away from the bone.
The complainants, some of whose children had found the ad distressing, challenged whether it was likely to cause fear and distress, and was inappropriate for display in an untargeted medium.
Norfolk Dinosaur Park Ltd explained that PrimEvil which was targeted at a teenage and adult audience, was an annual Halloween event that typically attracted 24,000 visitors over its 16-night run. They said the ad featured an illustration of a zombie and referred to a previous ASA ruling on a previous Norkfolk Dinosaur Park ad in which a similar image was found to be in breach of the Code. They said the ad under investigation was distinguishable from the previous ad because the character in that instance had been depicted in an aggressive manner while carrying a weapon, whereas the zombie had not. They highlighted the ad did not feature any violence or threat in the artwork used and was in line with similar visuals used at Halloween.
Norfolk Dinosaur Park said they had taken great care to ensure the ad had been placed away from areas where young children might congregate, such as near schools or on school run routes.
Clear Channel said their terms and conditions required that advertisers whose ads they carried were responsible for compliance with all relevant codes and laws of advertising. Clear Channel said that it was not for them to decide if the campaign was suitable for publication. Notwithstanding that, they applied a prohibition to the ad campaign to ensure that it was not played within 100 metres of any schools.
The ASA noted the ad had appeared at a poster site on a high street, and seven of the complainants had reported their children becoming distressed by the image. We acknowledged Norfolk Dinosaur Park’s comments that the character in the ad did not carry a weapon and was not displayed in a violent or threatening pose, and that the ad had been placed away from schools. However, we noted the character had realistic, recognisably human features, and that their flesh had rotted away to the bone, leaving blackened decomposing tissue, an exposed nasal cavity, and exposed teeth and gums. The character also had a large head wound, and blood from the wound ran down the side of their face. The character’s face was staring out, towards the viewer.
We considered the image was likely to distress young children, and that it was unsuitable for display where it was likely to be seen by them, particularly, but not only, in combination with the text “PRIMEVIL SCREAMING WON’T HELP!”, which was presented as though written in blood. We therefore concluded the ad had breached the Code.
The ad breached CAP Code (Edition 12) rules 1.3 (Social responsibility) and 4.2 (Harm and offence).
The ad must not appear again in the form complained of. We told Norfolk Dinosaur Park Ltd to ensure that future marketing that was likely to cause fear or distress to young children did not appear where they were likely to see it.