Four ads, for Rustlers convenience food, appeared on a range of different platforms.
- a. The VOD ad was shown on 4oD and ITV Player. The ad featured a woman, wearing a short butcher’s apron, stockings, suspenders and high heels, in a butcher’s shop. A sign on the wall behind her stated FIT AS A BUTCHER’S DAUGHTER . The woman said in a sultry voice, Hi there. I’ve something really satisfying to show you, so join me in my butcher’s shop. Dad’s left me in charge, which means we’ve got the place to ourselves. Just you, me and plenty of well-hung meat. The woman then pointed at on-screen text which stated Click for more and said, You know you want to. Clicking on the text took viewers to the advertiser’s website, http://www.rustlersonline.com.
- b. The ad appeared in an iPad game app.
- c. The ad appeared on YouTube
- d. The ad appeared on the MailOnline website
- e. The ad on the MailOnline and the local news website, http://www.thisissouthwales.co.uk, appeared next to an article. Text, written on a blackboard, stated Rustlers BOYS ARE ALWAYS COMPLIMENTING ME ON MY NICE RACK . The last two words were much larger than the preceding text. The woman from ad (a) danced into view with her back to the viewer, wiggling her bottom. She was wearing black knickers with the butcher’s apron, stockings and suspenders. She stopped, glanced suggestively over her shoulder towards the viewer, and winked. The text on the board changed to state FIT AS A BUTCHER’S DAUGHTER CLICK FOR MORE . The woman bent her knees and pointed at the viewer, kicked her leg back and walked off camera.
- f. The first ad on http://www.rustlersonline.com featured the same woman in the butcher’s shop, again speaking in a sultry voice, and emphasising certain words which could be taken as innuendo. She said, Oh yes, you know how the script goes, don’t you boys? Your starving mates keep coming over, so here’s some ideas for mouth watering, tasty treats to give them. Rustlers subs, Rustlers burgers on my lovely baps, or Rustlers wraps are sure to go down a storm and tackle their hunger. Containing no hydrogenated fat, we can trace your meat back to its farm of origin. She was shown stroking a large salami sausage. She continued, It’s flame-grilled and coated in my creamy mayo salsa or barbeque sauce, guaranteed to satisfy your drooling mouth. They’re quick and easy to cook and if you offer a touch of liquid refreshment too, the shout from your mates will be ‘I want some more’. A sign was shown which stated FIT AS A BUTCHER’S DAUGHTER Rustlers . The ad also included an interactive element; when website users hit numbers on their keyboard, the ad skipped to certain points throughout the ad.
- g. The second ad on http://www.rustlersonline.com also featured the same woman in the same setting, speaking in the same way and again emphasising certain words. She said, I want your full attention boys, because I’m going to tell you about what goes in to the great Rustlers range. We began in Ireland as a family butchers with a deep passion for making quality meat products for those who want good food, fast. We take pride in all that we do, because before I put something in my mouth I want to know where it’s been. The woman was shown stroking a sausage. She continued, So we always know where your meat has been farmed and reared, and from the barbeque sauce we put over succulent ribs to our creamy mayonnaise, everything we touch is handled with care. Our baps are fluffy and delicious. I pop my buns in the toaster so they don’t go too soft in the microwave. Maybe you should try that too. A sign was shown which stated FIT AS A BUTCHER’S DAUGHTER Rustlers . The ad included the same interactive element as ad (f).
The ASA received 18 complaints.
- All the complainants challenged whether the ads were offensive, because they were sexist to women and presented them as merely sex objects.
- Four complainants challenged whether ads (a) and (b) were appropriate to be seen by children.
1. Not upheld in relation to ads (a), (b), (c), (d) and (e)
The ASA noted the woman in the ads was wearing revealing clothing, that in ads (a) to (d) she used mild innuendo to encourage viewers to follow the link to the advertiser’s website, and that in ad (e) mild innuendo appeared on the blackboard beside her. We acknowledged that some viewers might find the ads distasteful, in part because there was only a tentative link between the product and the use of a woman wearing revealing clothing and using innuendo. However, we considered that the woman’s clothing, the language used, and the dance in ad (e), were not sexually provocative or explicit, and the ads did not present women merely as sex objects. We concluded ads (a), (b), (c), (d) and (e) were unlikely to cause serious or widespread offence.
Upheld in relation to ads (f) and (g)
We acknowledged the ads were similar in theme and appearance to ads (a) to (e). However, we considered that some of the innuendo in ads (f) and (g) was significantly stronger, particularly because it was emphasised by some of the woman’s actions, it was sexually provocative, and it was the focus of the ad rather than the information she gave about the product. We considered the overall effect of the ads was that the woman was presented as a sex object. We concluded the ads were likely to cause widespread offence as a result.
Notwithstanding that, we noted the interactive element of the ads could be used by website users to jump to certain words or phrases in the woman’s speech which, although likely to be considered as innuendo when the ad was viewed in full, became sexually explicit when combined in different orders by the user. We considered the interactivity therefore accentuated the presentation of the woman as merely a sex object. We concluded the interactive element to the ads was likely to cause both serious and widespread offence.
On this point, we investigated ads (a), (b), (c), (d) and (e) under CAP Code (Edition 12) rule 4.1 (Harm and offence), but did not find them in breach.
On this point, ads (f) and (g) breached CAP Code (Edition 12) rule 4.1 (Harm and offence).
2. Not upheld in relation to ad (a)
We understood the complainants’ concerns and agreed that the ad was not appropriate to be seen by children, because it contained sexual innuendo and the woman was wearing sexually suggestive clothing. However, we noted that none of the complainants had stated that they were aware of children who had seen the ad on VOD, and we considered that both Channel 4 and ITV had taken appropriate steps to prevent the ad from being viewed by children. We concluded that the VOD ad was not socially irresponsible.
Upheld in relation to ad (b)
For the reasons stated above, we considered the ad was not appropriate to be seen by children. We noted the audience to whom the ad had been targeted but were concerned it was likely that the ad had been served to consumers outside the target audience; for example, we understood that the complainants who had seen the ad during the iPad game and on news websites, which were media targeted by Kepak’s network advertising partner, were all female. We also understood that where targeting was based on online behaviour or even demographic data provided by an internet user, ads could only be targeted to individual devices or logins on those devices, rather than to specific consumers. We considered it was therefore likely that children, who often used devices owned by their parents, such as iPads, to play games or access the Internet, could have viewed the ad. We considered the advertiser should have taken greater care to ensure the ad could not be viewed by children, and concluded the targeting of the ad during the iPad game was not responsible advertising.
On this point, we investigated ad (a) under CAP Code (Edition 12) rule 1.3 (Responsible advertising), but did not find it in breach.
On this point, ad (b) breached CAP Code (Edition 12) rule 1.3 (Responsible advertising).