Child wellbeing should be a principal aspect of all our advertising strategies, whether our intention is to advertise to them or not. Here at Merkle, as a core member of the Conscious Ad Network (CAN), we ‘adhere to ASA guidance and put the interests of children first and foremost, ensuring that their wellbeing is considered within their (our client’s) strategies from the outset’.
We recognise that children are spending an increasing amount online, on devices that may belong to adults and on platforms that do not have age-gating. We should be prepared, know the guidance, and ensure we and our clients adapt good practise in relation to this area.
Children are exposed to more advertising than ever
It has already been established that children ‘are being exposed to more advertising and at a younger age’. This does not look likely to change any time soon. One of the many pandemic side effects is the increased use of screens to enable home-schooling or to keep children occupied in various states of pandemic lockdown. In 2019, children under 14 already spent an average time of 23 hours a week using online enabled devices. It is assumed that this time has increased based on stats from the US showing a 500% increase on screen time when comparing 2019 to 2020.
One acknowledgement of the increased screen time effect is that it is not ‘what children do online, but the content they encounter’. We should accept that this includes advertising. As such we have a continued responsibility to bear in mind the ASA’s & CAP’s guidelines here in the UK to ensure we have accountability as advertisers.
Alongside the increased screen time has been the increased ownership of devices (tablets & phones primarily). 10% of 6-year olds own tablet increasing to 88% by the age of 13. In addition to this, children under 13 will be accessing their parents or carers devices to go online (around 85% of children in this age group use a family/shared device) and will likely see advertising directed to their parents/carers that may cause harm to the well-being to children.
When thinking of advertising that create harms to the wellbeing of children, it is a common misconception to predominantly imagine examples like the IT film trailer being played during baby lullabies on Spotify and ads for age-restricted products (such as gambling). We know that it is ‘normalised’ advertising that most often creates harm to wellbeing. A recent topic of debate is online junk food advertising (aka HFSS). Not inappropriate in its content, but being held accountable for the rise in childhood obesity. The role that beauty and fashion advertising has played on the mental well-being of children (& teenagers) with the ‘exposure to unrealistic ‘ideal’ bodies through film, television, magazines, advertising and social media’ has also been in the spotlight.
The ASA & CAP have recognised in various studies and through upholding of complaints that specific guidelines to the wellbeing of children and the advertising they are encountering should be in place. It is up to us as advertisers to ensure compliance, not only to protect children online but also the protect the reputation of the brands we advertise for.
The advertising guidelines from CAP/ASA
As an advertiser of any product or service you should be aware of the guidelines that CAP and the ASA have compiled and take action on.
CAP guidelines for the under 12’s:
CAP has specific guidelines following a study of the effect of advertising on children under the age of 12.
“The guidance… responds to evidence on younger children’s level of critical understanding. It requires online ads directed at under 12s… to clarify up-front the identity and commercial intent of the marketer if it is not otherwise clear from the context. This may include certain paid vlogs, advergames and product placements.”
Essentially, if you are specifically advertising to under 12’s you should not assume that the child/ren will know that you are serving them an advert and should disclose this accordingly.
Guidelines in general for children:
The CAP Code goes on to provide rules regarding advertising aimed at or featuring children (defined as being under 16, with acknowledgement that 16/17 year olds should also not be targeted for age restricted products):
- ads must contain nothing that is likely to result in their physical, mental, or moral harm
- should not ‘actively encourage’ buying of your product
- children must not be shown in advertising to:
- enter strange places or talk to strangers
- be in hazardous situations or behaving dangerously
- using or close to dangerous substances or equipment without adult supervision
or encouraged to copy any practice that might be unsafe for a child
- ‘Alcohol, gambling, lottery and e-cigarette advertisers should also take care to ensure they are not directing their advertising at under-18s through the selection of media, style of presentation, content or context in which they appear’
The teenage consumer (the renowned next generation of money spenders for advertisers) falls under this category, and the ASA are clear in their guidelines that your marketing should not undermine parental authority. Similarly, any advertising should not suggest your product will make them popular or boost their credibility as a result of ownership.
How to control your advertising to children as an advertiser
The ASA regularly do a sweep of age-restricted product, weight control/slimming and HFSS advertising on websites that are intended for use by children or have an established demographic of children. Helpfully, they put together a list of websites that they monitor. This list would be a good place to start as an exclusion if you know you should not be advertising to children.
Social media sites are the only platforms that restrict access based on age (it is another conversation entirely about children faking their ages to obtain access and whether social media brings harm to children’s well-being). However, this is not reliable by itself. Take, for example, the Facebook Audience Network (FAN). Adults logging into social media whilst children are accessing age appropriate apps on their devices may get ads intended for the owner of the device/whoever is logged into social media using FAN targeting.
Paid search (& platforms that use search) do their best with the controls available. Google (inc. YouTube), Amazon Video, Apple Search Ads and Microsoft rely on their own parental controls (or Made for Kids alternatives) being activated to limit advertising to children. Like social media, this is contingent on children not using an adult’s device without parental controls or using voice search.
As it seems likely that increased screen time is here to stay, here are some high-level tips as an advertiser to protect a child’s well-being:
- If you are intending to advertise to children or their parents, ensure you comply with the ASA & CAP guidelines.
- It is safer to assume that if you are advertising to a parent intentionally that their child will see your ad: the likelihood is that they share devices.
- Parental controls and age-gating are not good enough barriers to protect the well-being of children. As media spenders we put trust in the media owners, DSPs and platforms to ensure their algorithm however with shared devices in use we need to put extra safety measures in place. QA your strategy and protect your brand, ask what you want your message to be to children and/or teenagers? It is unknown what Generation Alpha will be like in terms of brand loyalty, but it is probably not worth the risk to exclude them from your strategy.
- Look at the audiences make up that you are targeting.
- Pull together a list of websites and apps to exclude especially if you know you should not be including children in your demographic, apply these as exclusions from the start.
- Keep the ASA/CAP guidance in the fore front of your strategy and planning, there is a lot of movement here. We recommend a regular check in with their guidelines.
- Check and check again placements and search queries on a regular basis
- If you want to advertise to teenagers don’t forget the guidelines apply to you too
Please do get in touch if this is something that concerns you and your brand, we will be happy to help.