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Social Responsibility
irresponsible behaviour. The ASA has upheld complaints about social responsibility against a diverse range of … children. Social responsibility covers many things, and some sections of the Code have a specific … rule concerning social responsibility in a certain sector. The following topics and issues should be
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Social responsibility: Body image
non-surgical cosmetic procedures. See also Cosmetic Interventions: Social Responsibility.
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Cosmetic Interventions: Social Responsibility
Marketing communications must be prepared with a sense of responsibility to consumers and to society (Rule 1.3). In 2013, the ASA produced a Guidance Note on Cosmetic Interventions, which includes important sections on the Use of production techniques, Before and After photographs, Endorsements and Testimonials as well as social responsibility. The guidance was updated in 2021 to include information on the most recent scheduling and targeting restrictions for under 18’s (see 'Targeting & Children' below). Time-Limited Offers & Promotions Cosmetic Surgery as Prizes Trivialising Surgery Targeting & Children Body image & vulnerable groups Nudity Time-Limited Offers & Promotions The issue of preparing advertising for cosmetic interventions responsibly features heavily in a number of ASA rulings, often with respect to sales promotions. By their nature sales promotions will usually be time limited, and although the ASA has ruled that it is not necessarily irresponsible to offer surgery as a gift or a prize, marketers should take particular care when executing and administering sales promotions, especially prize draws or competitions. The short response time in an ad for a cosmetic surgery clinic which stated “But hurry, offer must end midnight this Friday the 23rd of November” was considered irresponsible because it trivialised the significant decision to have an invasive procedure (Liverpool Cosmetic Surgery Ltd, 20 March 2013). Similarly, the ASA upheld a complaint about a clinic’s promotional offer because it was emailed to consumers who may not have previously considered surgery and was only available for 24 hours, giving consumers insufficient time to consider the implications of surgery in full before committing (MyCityDeal Ltd, 23 November 2011). The ASA noted, that an ad for laser eye surgery which stated “2 days REMAINING ... Give the “Buy Now” button a cheeky wink before the lids close on today's deal” that respondents who became aware of the promotion towards the end of the week might only have a day to decide whether to purchase the deal. Even though there was a seven day cancellation policy from when the voucher was issued, during which time consumers could research the procedure, the time-limitation was considered to be irresponsible and likely to pressure consumers into making a decision to purchase laser eye surgery (LivingSocial Ltd, 3 October 2012). Additionally, in 2022, the ASA investigated a Black Friday Instagram post for Transform breast augmentation. The post stated “If you have been considering breast surgery and haven’t yet booked, there is no better time. We have Black Friday prices on breast surgery starting from just £5990. Click the link on our bio to book your free consultation”, and the advertiser argued that the post was targeted at those who were already considering surgery. Moreover, they confirmed the purchase process included a cooling-off period, so customers had room to change their mind. However, the ASA felt that not everyone who saw the ad would necessarily be considering surgery, and the wording “there is no better time” and “Black Friday” meant that customers would be rushed to make a decision for fear of missing out. The complaint was therefore upheld (Transform Hospital Group, 13 April 2022). In short, marketers should be careful when promoting time-limited offers for cosmetic surgery. They should ensure that consumers are not put under undue pressure to purchase, and that all those notified of the offer are given a reasonable amount of time to consider it (Liverpool Cosmetic Surgery, 21 August 2013). Countdown clocks and claims such as “Hurry, offer must end Friday” should not be used. See also Promotional Marketing. Cosmetic Surgery as Prizes As above, there is nothing specific prohibiting marketers from offering cosmetic surgery as a prize in a competition/prize draw, but advertisers are urged to ensure these promotions are responsible. Generally, the ASA is likely to look more favourably on marketers offering a strict consultation process and if it is made clear in the ad that a prize winner would only receive a treatment if after a consultation they are deemed suitable (Optical Express Westfield Ltd, 24 July 2013). Marketers who wish to offer cosmetic surgery as a prize in a competition or prize draw are urged to contact the Copy Advice team in the first instance. Trivialising Surgery When advertising generally, marketers must not portray cosmetic surgery as a flippant decision, and it should always be portrayed as something that requires time and thought – therefore, marketers should not use claims such as “safe”, “easy” or “risk free” because no surgery is without risk - in 2022, the ASA upheld a complaint about a Facebook post which stated “Our breast augmentations are an easy process…” (Linia Cosmetic Surgery, 4 May 2022). In 2014, a poster for the healthcare travel industry in Malaysia was found to breach the Code as it trivialised breast surgery and suggested it could be incorporated into a holiday (Medical Tourism Association, 18 February 2015). More recently, the ASA has found a number of ads for surgery in Turkey trivialised the procedures they offered by focusing more on the ‘vacation’ element of their services rather than the procedures (AsproMED, 27 September 2023, GET DHI Hair Clinic, 11 October 2023). Moreover, a complaint about an ad promoting surgical consultations as part of “Christmas festivities” was upheld for being irresponsible and providing the impression that surgery was a decision that could be undertaken lightly (Secret Surgery Ltd, 25 February 2015). In a similar vein, a 2023 investigation into a plastic surgery ad that asked “Are you ready for summer?” was found to trivialise the procedures by both rushing consumers to make an important decision and by giving the impression it was a quick and easy transformation and recovery (Aestheal Clinic, 11 October 2023). An ad for Vaser Liposuction stated, “The incisions are tiny, the fat gets sucked out and you recover within hours…I spent months trying to shift this in the gym and it was done in two hours…Had my breasts done at MYA, loved them, so had no second thoughts about going back to them for vaser… what would you Vaser?”. In this case, the ASA noted the presence of a consultation process and cooling off period - however, it considered that the ad suggested that a decision to undergo the procedure was a quick and simple, with minimal invasiveness and a faster recovery time compared with traditional liposuction. The overall impression of the ad was found to trivialise cosmetic surgery by not making clear that Vaser Liposuction was a procedure that might carry some of the same risks as traditional liposuction (MYA Cosmetic Surgery Ltd, 3 September 2014). More recently, the ASA investigated an email from Transform, which stated “What can surgery do for you?” and included subheadings “INCREASED ENERGY LEVELS/GLOWING SKIN/IMPROVED WELLBEING/GETTING MORE SLEEP/FEEL BETTER IN YOURSELF”. The ASA concluded that because certain elements referenced in the ad, such as glowing skin and better sleep, could not be obtained specifically through cosmetic surgery, the ad exaggerated the benefits of surgery, and in doing so, trivialised the decision to have a procedure (Transform Hospital Group Ltd, 11 May 2022). Targeting & Children Marketers are reminded that, in 2021, new rules were added (CAP Code rule 12.25 and BCAP Code rule 32.2.9) prohibiting the marketing of cosmetic interventions to under 18’s. See our Guidance Note on Cosmetic Interventions for more information about this, as well as our Targeting and Children: Targeting guidance, and Advertising Guidance - Age-restricted ads online . In 2024, the ASA invested two online display ads for MYA, a breast augmentation advertiser, which were seen on the website Quizlet, an online resource that provided study tools for students. The ASA found the latter website was aimed at all students, including those under 18, and concluded that the nature of the website meant a significant proportion of users would be aged under 18. As such, the ads breached the Code (MYA Clinics Ltd, 31 July 2024). Similarly, in late 2023, the ASA investigated ads for sun beds on TikTok which featured audio from the TV show Keeping Up With The Kardashians . Though the advertiser had the ability to target organic posts away from under 18s, they had not done so (Golden Tanning Salon Ltd, 13 December 2023). Body image & vulnerable groups In the past, the ASA upheld multiple investigations into whether cosmetic surgery ads were irresponsible by targeting young people or vulnerable groups, or generally exploiting consumer’s insecurities. From 2016-2018, the ASA investigated a number of ads for breast augmentation and found some harmful because they took advantage of young people’s insecurities (MYA Cosmetic Surgery Ltd, 19 April 2017 and TFHC Ltd t/a Transform, 6 July 2016) as well as a Transform TV ad which was seen to exploit the insecurities of new mothers (TFHC t/a Transform, 3 January 2018). Marketers must be careful not to exploit the insecurities of those seeing the ad. In 2023, the ASA investigated an ad for a “MOMMY MAKEOVER” which offered “3 Areas Liposuction – Tummy Tuck – Breast Lift”. The ASA concluded that the ad exploited the insecurities of mothers about their body image and perpetuated pressure for them to confirm to body image stereotypes (Grand Clinic, 11 October 2023). Ads for cosmetic surgery which portray individuals as only being socially confident and attractive because of surgery are unlikely to be acceptable (Cosmedicare UK Ltd, 3 April 2019), nor are ads that suggest that certain conditions, such as hair loss, could or should make individuals lose confidence (Clincexpert Hospital, 11 October 2023). Similarly, marketers must also not include claims or imagery that suggest someone is abnormal for not partaking in surgery. In 2016, the ASA upheld complaints that an ad was socially irresponsible because it offered “labia reshaping” for a “more natural appearance” (London Bridge Plastic Surgery Ltd, 11 May 2016). Advertisers should also be wary of strongly linking confidence and happiness with the decision to have cosmetic procedures. In 2024, the ASA investigated an Instagram post by Pall Mall Medical which stated, amongst other claims … and Objectification and Social Responsibility: Body Image for more. Whilst this is
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Advertising Guidance - misleading environmental claims and social responsibility
claims and social responsibility. The guidance was updated in June 2023. To find out more
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The Portman Group
The Portman Group, supported by the UK's leading drinks producers, is solely focused with the social responsibility issues surrounding alcohol.
social responsibility issues surrounding alcohol. The Portman Group’s Code of Practice … to: Promote best practice in alcohol social responsibility via actions by member
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Guidance on the trivialisation of short-term, high-cost credit in ads
Guidance for advertisers on how to ensure ads for short-term, high-interest loans are socially … responsible and don’t trivialise the seriousness of taking out a loan.
loans are socially responsible and do not trivialise the seriousness of taking out a loan. The
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Financial products and services: Credit Unions
considered subject to the Code? Social responsibility What aspects are considered subject to the … within the remit of the CAP Code. Issues such as offence, social responsibility, superiority claims, fear … . Social responsibility The Code states that all ads should be socially responsible by
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Female genital mutilation
marcoms offering the procedure are advised to seek legal advice. See also Legality and Social Responsibility.
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Financial products and services: Insurance
General insurance advertising is subject to statutory control by the Financial Conduct Authority (FCA) under the Financial Services and Markets Act 2000 and the Financial Services and Markets Act 2000 (Financial Promotion) Order 2005. The FCA regulates the technical aspects of non-broadcast insurance adverting. However “non-technical” aspects of insurance marcoms (for example, offence, social responsibility, superiority claims, fear and distress and competitor denigration) are likely to fall within the remit of the CAP Code. What products are considered ‘General Insurance’? Socially responsible Harm and offence Claims regarding non-technical aspects of the product Further guidance What products are considered ‘General Insurance’? General insurance products are those that are regulated by the FCA and include household, motor (including some car breakdown cover), travel, pet, payment protection, private medical insurance, term (life) assurance, critical illness … should be socially responsible by being prepared with a sense of responsibility to … . Socially
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Entertainment: General
, Weapons and Anti-Social Behaviour Targeting Social Responsibility and General offence Fear … Drugs’ below. Social responsibility and offence Whilst offence on the grounds of issues … . This is also the case for issues of social responsibility. As these issues can be nuanced, the ASA
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Financial products and services: Consumer credit
to the Code? Social responsibility for short term loans Irresponsible lending and Christmas … within the remit of the CAP Code. Social responsibility for short term loans Advertisers should … ads were looked at as part of wider piece of work on social responsibility in ads for loans offered
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Gambling, betting and gaming: Licensed casinos and non-gaming facilities
The Gambling Act & the CAP Code Ensure ads are socially responsible Non-gaming events or … Ireland or the Channel Islands. Ensure ads are socially responsible Ads for casinos or other … facilities where section 16 applies, should be socially responsible (16.1) and not should portray behaviour
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Weight control: Body wraps
rely on testimonials alone Take care when using before and after images Be socially responsible Distinguish … are being used with permission. See Before and after photos. Be socially responsible Ads
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Cosmetic surgery
, harming or offending the public, and ensure their ads are socially responsible. Misleadingness … Harm and Offence Targeting Social Responsibility Promotions Services offered abroad … Social Responsibility: Body Image. Targeting Marketers are reminded that new placement and
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Litigation: Claims management
-technical” aspects of ads for these companies. Matters relating to offence, social … responsibility, superiority claims, fear and distress, competitor denigration and claims that do not relate to
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Entertainment: Video games
Interactive Ltd, 9 April 2008). See Social Responsibility for more on this. Marketers … , distress and social responsibility Ads that feature scary or distressing images or sequences … , along with being generally socially responsible. In 2024, the ASA investigated an ad for
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Weight control: Medical procedures
might be offered in the UK or abroad. Substantiation Social responsibility Before and after … Clinic, 11 October 2023) See Cosmetic Interventions: social responsibility, Social … medically certified if it is not (Advanced Esthetics Solutions Ltd, 13 November 2013). Social
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Gambling, betting and gaming: General
you are unsure. CAP Code Section 16 (Gambling) Socially responsible Vulnerable consumers … products in Northern Ireland or the Channel Islands. Socially responsible The CAP Code … requires that all gambling advertising is socially responsible and advertisers should ensure they respect
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Crowd funding
-technical” aspects of ads for these companies, such as matters relating to offence, social … responsibility, superiority claims, fear and distress, competitor denigration and claims that do not
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Environmental claims: Carbon offsetting and carbon neutral
the updated CAP Advertising Guidance on The environment: misleading claims and social … responsibility in advertising, and the new e-learning module that covers the rules on Climate Change and the