ASA Watch

A poster, seen during June and July 2023, featured an image of the top half of model and influencer Eliza Rose Watson posing in a bra top. Text stated @ ELIZAROSEWATSON with the logos of the OnlyFans and Instagram social media platforms.

The ASA received 30 complaints:

1. All the complainants, who understood that OnlyFans was an internet content subscription service which featured sexual adult content, challenged whether the ad was inappropriate for display in an untargeted medium where children could see it.

2. Many of the complainants, who believed the ad was overly sexualised and objectified women, also challenged whether the ad was offensive, harmful and irresponsible.

Eliza Rose Watson said the ad adhered to advertising guidelines and reflected trends in leading brands. The development process took over a month, during which she ensured the ad was tailored to avoid offensiveness to mature viewers and intrigue to the younger generation. The image selected was evaluated by a diverse group, beyond those in the glamour industry. It was deemed to be non-suggestive, not harmful and less provocative than mainstream lingerie or perfume brand advertisements. Ms Watson provided examples of ads for clothing and condom brands which she believed were shown in busier areas of London. She said that, in her experience of social media channels, radio and TV discussions, a significant majority of consumers did not find the ad offensive.

The ad deliberately omitted any explicit website link or call to action, which was intended to veil the OnlyFans platform from those who may not be aware of it or wished to engage with it. The use of the OnlyFans logo was consistent with its appearance in mainstream media. Ms Watson provided images of a racing car and boxer showing the OnlyFans logo being featured on their clothing and car.

Amplify Outdoor said they never intended to cause offense by placing the ads but simply wished to provide a voice to a legitimate business that wanted to use their network. They believed most of the negative comments came with the increased media attention at the beginning of July. They said they had received one complaint direct.

ASA Assessment: Complaints not upheld

The ad featured an image of Eliza Rose Watson wearing a bra top which showed her cleavage. Her hair was tousled over her face and her mouth was slightly open. The ASA considered that although her clothing was revealing, the image did not feature any nudity, and the pose adopted by Ms Watson was no more than mildly sexual.

The ad also featured the Instagram and OnlyFans logos. We understood that the OnlyFans platform featured various kinds of creative content posted by subscribers to its service, including adult sexual content. Therefore, the image of Ms Watson would be particularly relevant to the OnlyFans service, and in keeping with some of its usual content. Both the Instagram and OnlyFans logos were the standard company logos which people who were familiar with those platforms would be familiar with seeing. Although the OnlyFans website featured explicit adult content, the ad did not feature any explicit imagery. The ad promoted Ms Watson and her business on online platforms. It did not contain anything which indicated an exploitative or degrading scenario or tone. While we acknowledged that the image of Ms Watson and reference to OnlyFans might be distasteful to some, we considered that because the ad was not overtly sexual and did not objectify women, we therefore concluded it was unlikely to cause serious or widespread offence.

The ad was shown on several posters throughout London, which was an untargeted medium, and was therefore likely to be seen by a large number of people, including children. However, because we considered the ad was not overtly sexual and did not objectify women, we therefore concluded the ad was unlikely to cause serious or widespread offence and had not been placed irresponsibly.

We investigated the ad under CAP Code (Edition 12) rules 1.3 (Social responsibility), 4.1 and 4.9 (Harm and offence), but did not find it in breach.

A pre-roll ad on YouTube, seen on 5 September 2022, for Wild deodorant, featured a woman sitting up in bed. She seemed to be masturbating under the bedcovers while watching a computer screen. She was interrupted by a talking polar bear which then joined her in bed.

A complainant, whose ten-year-old son saw the ad, challenged whether it had been irresponsibly targeted because it was seen before Minecraft videos which were likely to appeal to children.

Wild Cosmetics Ltd said they had taken care to avoid the ad being shown to a younger audience. They said they targeted their YouTube ads based on users' interests, for example health and beauty, and it was likely that someone deemed a prospective customer had been logged into the YouTube account at the time the ad was shown. They said they did not choose with which videos their ads were shown; this was controlled by algorithm. They said they did not advertise on channels that were clearly aimed at children and would add this channel to their list of exclusions.

ASA Assessment: Complaint upheld

We understood from the complainant that the ad had been shown on the DanTDM channel. The content for this channel included commentary videos about Minecraft, Roblox and Pokemon and was largely, although not exclusively, aimed at children and showed content that was likely to appeal to children. In light of the ad's reference to masturbation we considered that the ad should have been appropriately targeted to avoid the risk of children seeing it.

We noted the advertiser had targeted the ads based on the interests of potential customers and had excluded some channels. However, those exclusions had proved insufficient to prevent the ad from being seen around videos on DanTDM channel, before a Minecraft video. Because the ad appeared before a video likely to appeal to children, we concluded that it had been inappropriately targeted.

We concluded that the ad had been irresponsibly targeted.

We told Wild Cosmetics Ltd to ensure their ads were appropriately targeted and that ads that were unsuitable for viewing by children did not appear in media that was likely to appeal to children.

Two ads (one Instagram and one website) promoted a drinking card game.

a. A paid-for ad on Instagram, for a drinking card game, seen on 4 November 2022 stated, UK's most irresponsible drinking game Spice up your pre-drinks, parties, stag dos and hen dos with an easy to play but brutally exciting drinking game. Warning: This game is NOT for snowflakes and showed an image of a full beer glass with a face on the side which had crosses for eyes and a sloping mouth.

b. Ad (a) linked to a website which featured the beer glass with the face and stated HANGOVER GUARANTEED. DRUNKH is a no fuss, no bullshit drinking game. We've taken away confusing rules, because who understands those when you're pissed? Draw a card, do what it says. Brutal drinking game for parties, stag dos and hen dos. Get DRUNK with DRUNKH!

A complainant challenged whether ad (a) was irresponsible and the ASA challenged whether ad (b) was irresponsible because they:

1. encouraged excessive drinking;

2. portrayed drinking alcohol as a challenge, encouraged irresponsible and anti-social behaviour and linked alcohol with daring behaviour; and

3. suggested that alcohol was a key component to the success of a social event.

4. The complainant also challenged whether ad (a) was inappropriately targeted at people under 18 years of age. Response

DrunkH Ltd said they were new to the market and were not aware of the rules. They said they had ended all paid-for advertising for the game.

ASA Assessment: Complaint upheld:

The CAP Code stated that marketing communications must be socially responsible and must contain nothing that was likely to lead people to adopt styles of drinking that were unwise. It also stated that marketing communications which included a promotion must not imply, condone or encourage excessive consumption of alcohol.

We considered that the image of the beer glass with a face suggested someone who was inebriated, and the references to the UK's most irresponsible drinking game and The drinking game you'll never remember in ad (a) and the claims hangover guaranteed, when you're pissed and Get DRUNK in ad (b) condoned and encouraged excessive drinking and were therefore irresponsible and breached the Code.

We noted that the advertised game encouraged participants to drink alcohol and complete dares and considered lines such as UK's most irresponsible drinking game, brutally exciting drinking game, Warning: This game is NOT for snowflakes, Brutal drinking game, Not for the SNOWFLAKES, Not for the faint of heart and showing the dare cards portrayed drinking alcohol as a challenge. Furthermore, we considered that the ads encouraged people to behave in irresponsible and daring ways when drinking alcohol.

We considered that readers would understand the claim Spice up your pre-drinks, parties, stag dos and hen dos to mean that playing the drinking game was a significant factor in the success of those events or similar social events. Furthermore, we considered that the claims For the pre-drinkers, for the party goers, Not for the SNOWFLAKES to mean that drinking alcohol as part of the game was an integral part of the events. We therefore considered that the ad (a) implied that alcohol was a key component of the success of social events.

We understood that the ad had been served to people aged between 16 and 32 years and understood that it had not been directed only to people aged over 18. We concluded the advertisers had not taken sufficient care to ensure that the ad was not directed at people under 18 years and it therefore the ad breached the Code.

The ads must not appear again in the form complained of. We told DrunkH Ltd to ensure their future ads contained nothing that was likely to lead people to adopt styles of drinking that were unwise, encourage irresponsible or anti-social behaviour, portray drinking alcohol as a challenge or suggest that alcohol was a key component of the success of a social event. We also told them to ensure that ads referring to alcoholic drinks were not directed at people under 18 years of age.

A post on the Facebook page for Lee Andrews Male Grooming, seen on 21 June 2022, featured a cropped image of the lower half of a woman wearing a string bikini, lying on a beach. Pubic hair was seen to protrude from the bikini. Above the image, text stated, When spring comes and your [sic] not ready.

A complainant, who believed the image objectified women, challenged whether the ad was offensive and harmful.

Lee Andrews Male Grooming confirmed over the telephone that they believed the complaint was unfounded and did not objectify women.

ASA Assessment: Complaint upheld

The ASA noted that Lee Andrews Male Grooming provided grooming services and that, although their name referred to male grooming, they also provided waxing services for women, including bikini line waxing. We therefore acknowledged that the image was not entirely irrelevant to the service they offered.

However, we noted that the image was cropped from the waist down, removing the woman's head and making her groin and pubic hair the dominant focus of the image. We considered that focus used the woman's body to draw attention to the ad, and, in combination with the text in the ad, did so in a way that presented pubic hair as undesirable and the woman in the image as a subject of mockery. We considered that the image was likely to be seen as objectifying and demeaning women.

For these reasons we concluded that the ad was likely to cause serious and widespread offence.

The ad must not appear again in its current form. We told Lee Andrews Male Grooming to ensure that future ads did not cause serious or widespread offence by objectifying women.