A TV ad for Woburn Safari Park was seen on 25 August 2017. The ad began with a scene showing a car driving into Woburn Safari Park. The ad then depicted a young boy and a young girl looking out of the window from the backseats of a car. The ad then showed shots of different animals found in the safari park and also the young boy partaking in an outdoor adventure course. One of the final scenes showed both children asleep in the backseats of the car. The boy was shown to be in the window seat with a fastened seat belt visible and the girl was in the middle seat with her head resting on the boy’s shoulder.
The complainant, who believed that the children featured in the ad were not shown to be wearing seat belts properly, challenged whether the ad was irresponsible.
Woburn Enterprises Ltd t/a Woburn Safari Park stated that they did not believe the ad encouraged others not to wear a seat belt, or not to wear a seat belt properly. They pointed out that during the initial scenes in which the children were first shown, the car was in a stationary position in a grass car park. They said that there was no legislation which stated that children must wear a seat belt in a stationary car. They also pointed out that this scene was brief and 1.36 seconds in length, and it showed that the seat belt was worn around boy’s shoulder and therefore in the correct position. They said the seat belt shown was not prominent or the central focus of the shot.
Woburn Safari Park also stated that the appearance of the seat belt was not central to the concluding shots of the ad, in which both children were depicted in the car again. The message conveyed by those final scenes was that the children were tired and sleepy after a day of fun at the park. They stated that the girl in the middle seat had a seat belt across her lap, which was not shown in the ad.
Woburn Safari Park further stated that the fact that both children were wearing a seat belt in a stationary car on a grass car park on private land in both scenes demonstrated acceptable behaviour that was above and beyond the legal requirements. They said children wearing seat belts was not part of any key message of the ad and the content and context of the ad did not in any way suggest or influence a change in established behaviours, such as putting a seat belt on a child.
Clearcast said the first shot featuring the children was a close-up shot in which both children were seen to be looking out of the left window of the vehicle. They stated that the shot was so close that viewers would not be able to determine that a seat belt had not been worn. They said that as the children were clearly seen to be sitting in car seats, they would be wearing seat belts. They also pointed out that the car was stationary in that shot.
In relation to the second shot which featured the children in the car, Clearcast pointed out that both children were seen to be sleeping in the car. There was nothing to indicate that the girl was not wearing a seat belt, but that it had come around the other side of her body and was therefore not in view. However, Clearcast had confirmation that as the girl was shown to be in the middle seat, that particular vehicle had a lap belt which she was wearing. They said that in regards to the young boy asleep with the belt around him, it was visible from the ad that the belt came round from the side head rest, and was touching his jacket, which suggested that it was securely tightened, and that he was in a safe position.
The ASA noted that there were only two shots in the ad in which the children were briefly shown to be in the car: one at the beginning and one towards the end. In the first shot, the children were shown to be looking out of the left back car window. We noted that viewers could see an image of the back seats through the left back window and the angle of the camera was such that only the head and the neck area of the girl, who was positioned closest to the camera, were visible on screen. The boy was seen in the background and was slightly blurred. Because of the angle from which the seat belt would be fastened in his seat, it was not obviously visible if he was wearing a seat belt. The vehicle also appeared to be stationary in that scene.
In the shot towards the end of the ad, the children were briefly shown again in the vehicle that was moving slowly, and both were depicted to be sleeping. The girl was now seen to be in the middle seat and her head was resting on the boy’s shoulder, and the boy was leaning towards the car door, with only their heads and upper torsos visible on screen. The boy was depicted to be wearing a seat belt which was not tightly fastened, but not unsafely loose. It was not obvious whether or not the girl was wearing a three-point belt or a lap belt, because a close-up shot had been used in that scene.
We acknowledged that a visit to the safari park would involve driving through the park in a vehicle as depicted by the ad. However, we noted that both scenes in question were fleeting, and there were no scenes in which it was clear that the children were not wearing seatbelts, or had not fastened the seatbelts properly, in a moving vehicle. We considered that the main message of the ad was to convey the variety of animals that the children would be able to see, and the range of activities that they would be able to participate in during a day out at the safari park. The wearing of seatbelts, therefore, was incidental to that overall message. We also considered that the way in which the children were depicted in the car was unlikely to encourage viewers to disregard the importance of wearing seat belts.
For the above reasons, we considered that the ad was unlikely to condone or encourage a breach of the requirements of the Highway Code, and concluded that the ad was not irresponsible.
We investigated the ad under BCAP Code rules 1.2 (Responsible advertising), 4.4 (Harm and offence), 5.2 (Children) and 20.2 (Motoring), but did not find it in breach.
No further action required.