Insights Advertising Standards Authority considers recent rulings in relation to freely accessible gaming ads that children might see

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In November 2017, in response to concerns about gaming tiles on gambling sites that were freely accessible and which children may see, the ASA expanded its guidance on characters and graphics likely to hold particular appeal to children and that should be avoided.

The ASA has since ruled on some specific examples where ads promoting various games with graphical content were seen prior to a suitably robust age verification process. The ASA has now published a note examining the issues that arose in some of those cases and why some of the ads featuring animated images fell foul of the rules.

Believe what you may about fairies, the ASA says, but use them in gambling ads at your peril. Cute animated fairies, as well as more adult stylised fairies, were considered to break the rules. Even when the game title was spelt “Faeries” this did not deter the ASA from finding the ad problematic when coupled with an overall “fairy” theme. Ultimately, the ASA considered that fairies were popular amongst young children and the ads featuring them were likely to hold particular appeal to those under the age of 18. As such, the ASA advises avoiding the use of fairies where there is no suitably robust age-verification process.

The ASA explains that fairy tales are also likely to fall foul of the rules given their primary audience is children. In another recent ruling, “Hansel and Gretel” and “Little Red Riding Hood” had more than a hungry wolf and witch to worry about when the ASA ruled that the images used, along with the names “Fairytale Legends Red Riding Hood” and “Fairytale Legends Hansel and Gretel” were, perhaps unsurprisingly, “based on a popular children’s fairy tale story”, and therefore likely to be of particular appeal to children. On that basis the ASA advises “extreme caution” when it comes to creating gambling ads based on fairy tale themes.

The same is true of princes and princesses and graphics and images that make a character resemble those from “princess” themed films, the ASA says. Such ads are likely to be quickly dethroned. When assessing the game tile “Robyn”, the ASA considered that her large head, thin neck, large eyes, small nose and wavy long blonde hair were similar in style to that of “princess” themed films aimed at children. Therefore, the ad was considered likely to appeal particularly to under-18s.

As for depicting Santa, the ASA concluded that a generic use of the name in and of itself is not likely to hold particularly appeal to children. However, if you depict him in a particularly child-friendly way or introduce other appealing characters, such as Santa Paws or cute, cuddly polar bears, penguins and rabbits then, the ASA says, you shall end up on the ASA’s naughty list (and maybe even Santa’s too).

Finally, when considering a Facebook post featuring an anime-style cartoon woman, despite having bright colours and cartoon imagery, the ASA considered this unlikely to appeal more to children than it did to adults. It took the view that, in its broadest sense, anime/manga is generally aimed at an adult audience. Therefore, cartoon images and animation are not, in and of themselves, necessarily an issue; it is more the style that should be considered. However, obviously, if it is reminiscent of a particular anime or manga series that is aimed at children or well known for its popularity amongst children, it is better to steer well clear. To read the ASA’s note in full, click here.