Ad description

The Pretty Little Thing website, seen 1 June 2022, featured Alabama Barker as a brand ambassador, along with her “Y2K Edit” clothing collection.

The brand ambassador webpage featured the headline “Y2K IS CALLING”, under which text stated, “channel that teen dream realness with barely-there micro mini skirts”. The page also included a series of images of Ms Barker modelling clothing from her edit. In one image, Ms Barker wore a tight-fitting short dress whilst sucking a lollipop. Another image featured Ms Barker wearing high heels and a low-cut short dress that revealed her breasts whilst spraying a water hose. Ms Barker was also shown wearing a dress taking a phone call whilst lying on a bed and licking her lips. Further images showed Ms Barker in a short V-necked dress clutching her chest with one hand, and posed with her leg bent wearing a mini skirt and knee high boots. An image of an open mouth with the tongue hanging out also featured.

On the product page for the clothing collection text stated, “Nail the latest trends and team a cropped varsity jacket with a mini skirt and knee-high boots for a date with your best dolls or flaunt your curves in a white figure-hugging dress … Alabama Barker is here to make sure you’re feeling confident and looking fierce.” The page featured several products modelled by Ms Barker. One such image showed Ms Barker wearing a miniskirt, shirt and corset top whilst reclining on a bed and holding a handbag in the air. Another image featured Ms Barker wearing fluffy hair clips, a white cropped shirt, exposing her midriff, and sunglasses emblazoned with the text “THAT’S HOT”. In another image, Ms Barker wore a mini skirt, vest and cropped jacket whilst bent forward and clutching her chest.


The complainant, who believed that Alabama Barker was 16 years old, challenged whether the ad breached the Code by portraying someone who was under 18 in a sexual way.

Response Ltd confirmed that Ms Barker was 16 years old at the time of the ad’s shooting. They said that they had chosen Ms Barker as their brand ambassador because their customer base was primarily aged between 16 and 24 years old. They said that the campaign was based on the “Y2K” trend which they said was extremely popular with their target market and which they characterised as girly, colourful, fun and playful.

PrettyLittleThing said that they did not intend to sexualise Ms Barker and disagreed that she was portrayed in a sexual manner. They said that all creative was approved by Ms Barker and her team, and that she was posed in a similar style to images that could be seen on her own Instagram account. They said that the images in which Ms Barker was sucking a lollipop were intended as a nod to the Y2K trend and were playful and girly. They said, in reference to the images in which Ms Barker could be seen spraying a hose pipe, that they believed cooling down on the lawn on a hot day fitted the intended Y2K aesthetic. They said that Ms Barker was not asked to clutch her chest for the purposes of the photoshoot, and that in some cases her hands were held up close to the body to hold a jacket in place. They said that the use of open-mouth poses was currently popular with young people on social media, and some of these images were captured whilst Ms Barker was talking to the photographer.

Finally, PrettyLittleThing said that they wanted to convey a message of body positivity to encourage and empower young women to embrace their bodies and inspire confidence.



The CAP Code stated that marketing communications must not portray or represent anyone who was, or seemed to be, under 18 in a sexual way.

The ASA understood that Ms Barker was aged 16 years old at the time of shooting and we considered that she also looked under 18 in the images. We noted that Ms Barker was shown in a number of different outfits and wore items such as a tight-fitting short dress, a low-cut short dress that revealed her breasts, a corset top, mini skirt and knee-high boots. We considered the clothing to be revealing. We also noted that Ms Barker wore sunglasses emblazoned with the text “THAT’S HOT”, which we considered to be a reference to sexual or passionate feeling.

We considered that a number of her poses were also likely to be considered as sexual. In several images, Ms Barker was shown lying on a bed and in one of them she was licking her lips in a sexually suggestive manner. Several of the images in which she was wearing a mini skirt involved Ms Barker crouching down, or bending her leg, which accentuated the prominence of her upper thighs, to the extent that her buttocks were almost visible. Furthermore, we noted that in another image Ms Barker was shown spraying a water hose which was positioned between her legs, which we considered focused the eye to her crotch area. In other images, Ms Barker was shown sucking a lollipop and clutching her chest.

We also considered that the text “channel that teen dream realness with barely-there micro mini skirts” further highlighted Ms Barker’s young age. The references to “barely-there micro mini skirts” were also likely to be seen as sexualised.Given the above, we considered that the ad depicted a person who was under 18 in a sexual way, and we therefore concluded it was irresponsible and breached the Code.

The ad breached CAP Code (Edition 12) rules  1.3 1.3 Advertisements must comply with the law and broadcasters must make that a condition of acceptance.  (Social responsibility) and  4.8 4.8 Advertisements must not condone or encourage harmful discriminatory behaviour or treatment. Advertisements must not prejudice respect for human dignity.  (Harm and Offence).


The ad must not appear in its current form. We told Ltd to ensure future ads did not include images that portrayed or represented anyone who was, or seemed to be, under 18 in a sexual manner.


1.3     4.1     4.8    

CAP Code (Edition 12)

1.3     4.1     4.8    

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