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Avatar Alert! ASA uses child avatars to tackle irresponsible ads targeted at children

15 October 2019. Published by Oliver Bray, Partner and Victoria Noto, Associate

The ASA is proactively using avatars (which mimic child-like behaviour) to identify when age-restricted ads (gambling, alcohol, HFSS etc) are being irresponsibly targeted at children.

The introduction of this new technology has already had an impact on ad monitoring and enforcement.

The twist

Retailers of products which are subject to advertising age restrictions (gambling, alcohol, HFSS etc) must make sure that their business or any company which their business uses to place their ads takes sufficient measures to keep ads which promote these products from being directed at children. This is the case even if the ad is not offensive and is therefore unlikely to attract a complaint - the introduction of avatars means that no wrongly placed ad is safe from the watching eyes of the ASA’s avatar operators!

Why is this important for retailers?

The use of new technology will enable the ASA to be more proactive in taking action against retailers for irresponsible ad placement as they will be in a better position to easily identify this without having to rely on receiving a complaint from a member of the public. This in turn will facilitate the ASA in being able to take swift action against the responsible parties - as was shown by the action taken against the non-compliant gambling operators and HFSS brands identified by the avatars to date. 

The development

According to Guy Parker, the ASA’s Chief Exec, one of the key focal points for the ASA’s current five year strategy is to “strengthen further the regulation of online advertising and using new tech to protect the public”. The use of these child avatars which simulate children’s online behaviour in order to monitor the types of ads that children are prone to see online appears to be the first example of the ASA introducing new technology to improve its enforcement capabilities in accordance with this strategy. 

Digging deeper 

The ASA, with the assistance of a data and analytics company, initially formulated seven online avatars which simulated the behaviour (on non-logged-in-environments) of children of varying ages, an adult, and a child and an adult using the same device. 

As a result of these avatars, the ASA announced in April 2019 that it had banned ads from five gambling operators whose ads were served to the child avatars. During a two week period where the ads were monitored, the ASA found that out of 24 children’s websites monitored, 11 showed gambling ads.

The bookmakers responsible for the ads have accepted that their ads should not have been available to children on those sites, but sought to place responsibility onto third parties who had wrongly placed the ads on behalf of the gambling operators. The ASA has informed these companies that they must review the placement of their ads and take appropriate measures to make sure the mistake is not repeated.

Following the successful outcome of this monitoring, in June 2019 the ASA announced the outcome of further avatar simulations in order to examine whether HFSS product ads were appearing on YouTube and children's websites. The exercise found that whilst retailers were generally being compliant with advertising rules, there were instances on some websites and YouTube channels where there were breaches of the Code. Again, the infringing brands were contacted by CAP to take steps to remove the offending ads and to provide details of the mechanisms that they had in place to ensure that future ads were not inappropriately targeted at children. 

These developments clearly show that the ASA is effectively using the avatar monitoring techniques to bolster its enforcement capabilities. The ASA has already confirmed that it also intends to deploy the avatar technology to logged-in environments, in particular social media channels. CAP has also committed to updating its Guidance on Children and Age-restricted Ads Online and roll out additional training and workshops on this topic. With this in mind, we are likely to see further use of the avatar technology very soon – likely across the alcohol sector and on social media.