A website for Discount Double Glazing, www.localdoubleglazing.co, seen 26 March 2019, included a headline which stated “Let us find the cheapest double glazing prices to compare”. Smaller text underneath stated “Start comparing replacement windows prices” above a link which stated “Compare Prices Now”. At the bottom of the page text stated the company was a FENSA “Registered Company” and that it was “recommended” by the Energy Saving Trust. The ad included other logos for Certass, the Glass and Glazing Federation and the Double Glazing Ombudsman Scheme.
1. The complainant challenged whether the ad misleadingly implied the company had been approved or endorsed by the bodies featured in the ad and was signatory to a code of conduct.
2. The ASA challenged whether the ad falsely implied that the marketer was acting for purposes outside its business.
The Lead Guys Ltd t/a Discount Double Glazing did not respond to the ASA’s enquiries.
The ASA was concerned by The Lead Guys Ltd t/a Discount Double Glazing’s lack of response and apparent disregard for the Code, which was a breach of CAP Code (Edition 12) rule 1.7 (Unreasonable delay). We reminded them of their responsibility to respond promptly to our enquiries and told them to do so in future.
We considered that consumers would understand the inclusion of the logos for FENSA, the Energy Saving Trust, Certass, the Glass and Glazing Federation and the Double Glazing Ombudsman Scheme as an indication that Discount Double Glazing were accredited by those organisations and that they were a signatory to any code of conduct required by them. Because Discount Double Glazing did not provide any evidence that they held such accreditation, we concluded that the ad was misleading.
On that point, the ad breached CAP Code (Edition 12) rules 3.50 and 3.51 (Endorsements and testimonials).
The website home page included the headline claim “Let us find the cheapest double glazing prices to compare”, below which was the claim “Start comparing replacement windows prices” and the call to action “Compare Prices Now”. In smaller text the ad stated “We work with the largest network of replacement windows contractors. Meaning we will find you more prices to compare” and “Compare prices for your new replacement windows now and we will help you to find you the cheapest prices”.
At the bottom of the home page, text stated “We work with local manufacturers of double glazing units and the fitters that work in your local area, so we can honour or [sic] commitment to finding you the right new double glazing for your home, at the best price with your local service”.
We considered consumers would understand that the website was an independent price comparison service for double glazing where they could submit details of the work they wanted completed, following which they would receive a number of customised estimates from a range of companies based on the details they submitted. However, we understood the website was operated by a lead generation firm, which instead sold consumers’ details to third parties who had paid to receive leads generated by the ad. Therefore, because the Discount Double Glazing website presented itself as an independent price comparison service for double glazing when the purpose of the website was to generate leads that were sold to another company, we concluded that the ad breached the Code.
On that point, the ad breached CAP Code (Edition 12) rule 2.3 (Recognition of marketing communications).
The ad must not appear again in its current form. We told The Lead Guys Ltd t/a Discount Double Glazing not to claim or imply they had been approved by any public or other body if they had not. We also told them to ensure their ads did not falsely imply that they were acting for purposes outside their trade, for example by presenting websites designed to generate leads for other companies as independent comparison websites. We referred the matter to the CAP Compliance team.