Ad description
A radio ad for car insurance featured the following exchange between comedian, Dawn French and the brand mascot Churchill, "Eighty?", "Oh Yes", "Eighty?", "That's right", "Eighty?", "Eh, eighty", "Sorry, eighty?", "Erm, yes", "Eight-Ee?", "Eight Zero", "Yes", "That's alright I suppose". This exchange was followed by a voice-over, which stated "For 80% off your car insurance if you have an eight-year no claim discount, chat to Churchill. Applies to new customers for the first year. Most customers achieved this discount."
Issue
The complainant, who had obtained several cheaper insurance quotes and believed Churchill had inflated their prices, challenged whether the saving claim was misleading.
Response
Churchill provided screenshots of five insurance quote examples before and after an eight-year no claim discount had been applied to the consumer's details. Three of the screenshots showed an 80% discount on the original price, one showed a 79.9% discount and one showed a 78.2% discount. They said the details entered for each quote were the same, except for the no claims bonus. They said that the savings claim made it clear that most new customers with an eight-year no claims discount would benefit from an 80% discount. They said that they had used the term "most" because of the limited time in the ad and because it would be understood to mean that not all customers achieved the discount. They also provided data on the proportion of consumers who had achieved the discount. Churchill said that while they had previously expected 81% to do so, 89% of new customers were now currently receiving the discount.
The RACC provided written assurance from Churchill that the offer was an 80% discount for new customers with eight years or more no claims discount. It also stated that over 81% of customers achieved the full 80% discount stated within their first insurance year. The RACC said that they believed the basis of the claim was transparent to consumers and it would be interpreted to mean that a new customer with an eight-year no claim discount would benefit from an 80% discount, compared to an existing customer. They said 81% represented "most customers" and that the advertiser had therefore provided sufficient evidence to substantiate the claim.
Assessment
Not Upheld
The ASA considered the claim would be understood by listeners to mean Churchill could offer new customers a discount on its own insurance, rather than that they offered rates that were 80% cheaper than all competitors. We acknowledged that Churchill had provided evidence to show that a significant discount was available on the standard price if a new customer had an eight-year no claim discount. We noted that in three out of the five examples provided, the discount was exactly 80%, whilst, in the other two examples, the discount was very close to 80%. We also noted that the ad stated that "most customers" had achieved the discount and that Churchill had provided evidence to demonstrate that was the case. We considered 81%, or greater, as was the case for some months, to be a sufficient proportion of customers to substantiate that claim. Because we considered that Churchill had provided sufficient documentary evidence to substantiate the claim, we concluded that the ad was not misleading.
We investigated the ad under BCAP Code rules 3.1 3.1 Advertisements must not materially mislead or be likely to do so. (Misleading advertising), 3.9 3.9 Broadcasters must hold documentary evidence to prove claims that the audience is likely to regard as objective and that are capable of objective substantiation. The ASA may regard claims as misleading in the absence of adequate substantiation. (Substantiation), 3.18 3.18 Price statements must not mislead by omission, undue emphasis or distortion. They must relate to the product or service depicted in the advertisement. (Prices) and 3.40 (Price Comparisons), but did not find it in breach.
Action
No further action necessary.
