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August 4, 2014
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Introduction
Amongst other things, this week we report on the news that the Article 29 Data Protection Working Party has met with search engines in connection with the recent decision of the Court of Justice of the European Union in the Google Spain case regarding the “right to be forgotten” to find out how they are implementing the ruling. Meanwhile, the Index on Censorship’s has written to the Article 29 Working Party about its concerns with the decision. The update also includes the Court of Appeal’s decision in The Environment Agency v Churngold Recycling Ltd in which the court found that electronically stored information is not susceptible to the tort of conversion: in other words, electronically stored information is not a chattel. Meanwhile, the Advertising Standards Authority has reminded competitors that they must try to resolve complaints between them before involving the regulator. The ASA has also published an update on its complaint-handling procedures. Ofcom has been busy this week, publishing a report for the Government outlining the measures that UK ISPs have put in place to help parents protect children from harmful content online, as well as the results of its research into how consumers view communications services in UK and their affordability. Ofcom has also published a call for input into the “Internet of Things”. Finally, the update includes a couple of interesting High Court general commercial contract decisions as well as a couple of interesting ASA decisions.
High Court enforces agreement to have “friendly discussion” before proceeding with arbitration.
High Court declines to make Norwich Pharmacal order on grounds of balance of irreparable harm.
European Commission publishes report on telecommunications market and regulation in EU.
Court of Appeal confirms electronically stored information not susceptible to tort of conversion.
Council of European Union adopts new electronic identification Regulation repealing E-Signatures Directive (1999/93/EC).
Ofcom publishes report for Government outlining measures UK ISPs have put in place to help parents protect children from harmful content online.
Ofcom publishes results of research into how consumers view communications services in UK and their affordability.
Ofcom publishes call for input into “Internet of Things”.
Article 29 Data Protection Working Party representatives meet with search engines on “right to be forgotten”.
Index on Censorship writes to Article 29 Data Protection Working Party over concerns with “right to be forgotten” ruling in Google Spain CJEU decision.
Ofcom launches review of signing arrangements for relevant TV channels.
Technology Innovation for Smart Publishing launches policy recommendations to boost innovation in book publishing and ICT.
Advertising Standards Authority finds 888 Casino’s “£88 Free” ads misleading because winnings and withdrawals restrictions were not given sufficient prominence.
European Commission and Member States take joint action on in-app purchases.
Advertising Standards Authority reminds competitors they must try to resolve complaints between them before involving the regulator.
Advertising Standards Authority updates complaint-handling procedures.
Advertising Standards Authority finds Diageo’s “Captain Morgan” ad implied alcohol could overcome boredom and was capable of changing mood.
High Court enforces agreement to have “friendly discussion” before proceeding with arbitration.
In a dispute between the supplier and the purchaser of iron ore, Teare J was required to consider an unusual dispute resolution clause that provided that if a dispute arose the parties shall “first seek to resolve the dispute or claim by friendly discussion… If no solution can be arrived at in between the Parties for a continuous period of 4 (four) weeks then the non-defaulting party can invoke the arbitration clause and refer the disputes to arbitration”. Teare J found that this was an enforceable provision that required the parties to have formal discussions in good faith before proceeding with arbitration. The judge gave particular weight to public policy considerations and distinguished earlier decisions on the basis that the clause in question was a dispute resolution clause, rather than an agreement to negotiate further agreements.
In the field of dispute resolution clauses the judge said that the court ought not to regard an obligation to seek to resolve a dispute in good faith as inherently inconsistent with the position of a negotiating party as it is not inconsistent where there is a material, voluntarily accepted, restraint on the parties’ freedom of action, namely, a promise to seek to resolve a dispute by friendly discussions in good faith. Further, finding that the obligation was enforceable was, in the judge’s view, consistent with the public policy of encouraging parties to resolve disputes without the need for expensive arbitration or litigation, as well as upholding the legitimate interests of commercial people that their agreements will be upheld by the courts (Emirates Trading Agency LLC v Prime Mineral Exports Private Ltd [2014] EWHC 2104 (1 July 2014) – to read the full judgment click here).
High Court declines to make Norwich Pharmacal order on grounds of balance of irreparable harm.
The Intellectual Property Enterprise Court has rejected an application by Wilko Retail Ltd for a Norwich Pharmacal order requiring the defendant, Buyology Ltd, to disclose the contact details of its suppliers who had supplied it with infringing goods bearing the WILKO trade mark. The court found that the parties had agreed to settle the trade mark and passing off claims by way of agreement to enter into a consent order. This binding agreement did not, however, preclude Wilko from applying to the court seeking a Norwich Pharmacal order since the disclosure element of Wilko’s claim was not pleaded in the Particulars of Claim, nor was it mentioned in the consent order. It was therefore a separate application, but still within the context of the proceedings that were still on foot. Nonetheless, HHJ Hacon declined to actually make the order for disclosure on the grounds that on the balance of irreparable harm, if such an order were made, Buyology could incur serious reputational damage as its suppliers would be concerned about future claims and might cease to supply. (Wilko Retail Ltd v Buyology Ltd [2014] EWHC 2221 (IPEC) (7 July 2014) – to read the judgment in full, click here).
European Commission publishes report on telecommunications market and regulation in EU.
The report shows that investment in the field is starting to grow again and that data traffic is growing quickly, with an increase in VoIP calls. However, huge discrepancies still exist among EU countries.
The main findings of the report:
- industry revenues again declined in 2013 but investment is beginning to grow;
- use of traditional telephony services is decreasing as internet (VoIP) services become increasingly popular;
- data traffic is growing quickly; and
- mobile voice call and data prices are higher in the EU than in the US, while the usage of mobile is higher in the US, resulting in a higher “average revenue per user” in the US.
Only Denmark, Germany, Latvia and Malta met the 2012 target for the authorisation of the specific spectrum bands. 21 Member States did eventually meet the target in 2013, but the delay in assignment of the 800 MHz band has significantly slowed the roll-out of 4G mobile across the EU.
The time needed to obtain permits to roll-out new networks ranges from a few days to years depending on where in the EU the network is being built. Most authorities still do not allow for electronic submission of requests.
European Commissioner, Neelie Kroes, said: “We are clearly still a long way from a real single market. We need to cut red tape and we need more consistent regulatory action at both national and EU levels; the implementation of the Broadband Cost Reduction Directive will contribute to this objective but there is more to do”. For further information, click here.
Court of Appeal confirms electronically stored information not susceptible to tort of conversion.
The Court of Appeal has allowed an appeal from a decision of His Honour Judge Havelock-Allan QC, on a claim under s 4 of the Torts (Interference with Goods) Act 1977, finding that the Environment Agency was not entitled to retain copies of documents and electronic data taken during the course of a criminal investigation at the claimant’s premises. Lord Justice Moses reiterated that information held electronically, as opposed to the media in which it is stored, is not a chattel and accordingly cannot be subject to the tort of conversion. Moses LJ acknowledged that there is a “powerful case” for recognising that the essential elements of possession could be exercised over digitised material “and that the dichotomy between choses in possession and choses in action and the recognition of a third category of intangible property susceptible to possession should be reconsidered”. Nonetheless, he considered that his hands were tied by the decision in Your Response Ltd v Data Team Business Media Ltd [2014] EWCA Civ 281, which cited OBG v Allan [2008] 1 AC 1 as authority for the proposition that the essence of conversion is a wrongful interference with possession of tangible property and that the common law draws a sharp distinction between tangible and intangible property (The Environment Agency v Churngold Recycling Ltd [2014] EWCA Civ 909 (4 July 2014) – to read the full judgment click here).
Council of European Union adopts new electronic identification Regulation repealing E-Signatures Directive (1999/93/EC).
The Council has adopted a new Regulation which lays down conditions for the mutual recognition of electronic identification; sets rules for trust services, in particular for electronic transactions; and creates a legal framework for electronic signatures, seals and time stamps, electronic documents, as well as for electronic registered delivery services and certificate services for website authentication. The Regulation will enter into force 20 days after its publication in the EU Official Journal.
The new Regulation provides a common foundation for secure electronic interaction between businesses, citizens and public authorities. It seeks to increase the effectiveness of public and private online services, electronic business and electronic commerce in the EU and to enhance trust in electronic transactions in the internal market.
The new Regulation requires Member States to recognise, under certain conditions, means of electronic identification of natural and legal persons falling under another Member State’s electronic identification scheme that has been notified to the Commission. It is up to Member States to choose whether they want to notify all, some or none of the electronic identification schemes used at national level.
The new rules only cover cross-border aspects of electronic identification. Issuing the means of electronic identification remains a matter for Member States.
Those Member States, which so wish may join the scheme for recognising each others’ notified e-identification, means as soon as the necessary implementing acts are in place. This is expected to take place in the second half of 2015. The mandatory mutual recognition is expected to kick off in the second half of 2018.
Until now, there were EU provisions only on electronic signatures, laid down in the 1999 Directive, which is repealed with effect from July 2016.
In addition to enhancing and expanding the e-signature provisions, the new Regulation also introduces, for the first time, EU-wide rules concerning trust services, such as the creation and verification of electronic time stamps and electronic registered delivery services, or the creation and validation of certificates for website authentication. Trust services that comply with the Regulation can circulate freely within the single market. In addition, an EU trust mark will be created to identify trust services that meet certain strict requirements. The use of the trust mark will be voluntary. To read the Council’s press release in full, click here.
Ofcom publishes report for Government outlining measures UK ISPs have put in place to help parents protect children from harmful content online.
Publication of the report follows an agreement between the Government and BT, Sky, TalkTalk and Virgin Media. Each ISP committed to offer new customers “family-friendly network-level filtering” by the end of December 2013.
This is the second of three reports the Department for Culture, Media and Sport has asked Ofcom to produce on internet safety measures to protect children. The DCMS asked Ofcom to look at the approach taken by each ISP to implement family-friendly filtering services which block content that may be inappropriate or harmful for children, rather than assess the effectiveness of the filters.
The report also describes measures taken by ISPs to present a pre-ticked “unavoidable choice” to new customers on whether or not to activate the filter, and includes initial take-up data among new customers offered filters. The filters apply to all web based internet content, on any device that is connected to the fixed broadband network in the home.
The report finds that the four ISPs now have a network level family friendly filtering service, which is offered to new customers. New subscribers receive a prompt from their ISP during the broadband set-up process, describing the filtering service and offering the consumer a pre-ticked option to use the filtering service.
The four ISPs are currently working towards meeting their commitment to Government to contact all their existing customers and present them with an unavoidable choice about whether or not to install the family friendly content filters by the end of 2014.
Ofcom is due to produce the third in the series of reports in December 2014. This will review Ofcom’s Media Literacy research from 2014 on parental strategies for protecting children online. To read Ofcom’s press release in full, click here.
Ofcom publishes results of research into how consumers view communications services in UK and their affordability.
The study examined which communications services UK consumers considered “essential” in their day-to-day lives and whether they are affordable, particularly for the most vulnerable in society.
There was broad consensus among consumers on what “essential” means in relation to communications services. People said the ability to contact the emergency services, keep in touch with family and friends, or access information, education and entertainment were among the key functions of essential services. Overall, the study found that telephone services, in particular mobiles, and internet access were most essential to UK consumers. Some 61% of consumers rated voice services (mobile or landline) as essential, 59% considered mobile voice or text services as essential, while 57% regarded personal internet access as essential.
The research also revealed that certain services were considered essential by some, but less important by others, with age being a key factor. Landline telephone services were considered essential by people aged 75 and above (61%), compared to just 12% of 16-24 year olds. However, accessing the internet via a smartphone was considered essential to 53% of 16-24 year olds, but to no one aged 75 and above.
Ofcom also examined the affordability of essential communications services. Among those consumers who said they were responsible for paying for them, 86% said they never had difficulties meeting the costs. This is consistent with previous Ofcom research showing that consumers had benefitted from falling prices and an increase in choice and quality over the last 10 years.
Of the minority (14%) that have had difficulties paying for communications services, three quarters (74%) have been careful about spending while managing their communications costs; just under half (45%) have cut back on luxuries; while around a third (36%) opt for cheaper goods or services.
The research found there to be low awareness of affordable deals among low income users and just 26% of consumers on income support knew about social landline tariffs offered by BT and KCOM. To read Ofcom’s press release in full and for a link to the study, click here.
Ofcom publishes call for input into “Internet of Things”.
The Internet of Things (IoT) is set to enable large numbers of previously unconnected devices to communicate and share data with one another.
The aim of the call for input is to allow Ofcom to develop a better understanding of the recent developments in IoT applications, standards and networks and of the role that Ofcom needs to play to ensure that the UK takes a leading role in the emergence of the IoT.
In particular, Ofcom says that it would like to form a more detailed view on the following points:
- the scale and nature of demand for spectrum, including how much additional spectrum may be required to support the IoT, if any; which frequency bands may be suitable; and whether an approach based on licensed or licence exempt access to spectrum is more appropriate;
- understanding more about issues relating to network resilience and security. A specific and important aspect of network security is privacy of personal or commercially sensitive data. There will likely be a number of privacy issues and the IoT will only flourish if these are addressed;
- IoT devices will need to be assigned one or more addresses in order to communicate with other devices. A number of address types could be used, including telephone numbers or Internet Protocol addresses. The type of address may depend on the network to which the device is connected and whether the device requires access to the global internet, or a local, private network; and
- the nature of Ofcom’s role. Generally, Ofcom’s view is that industry is best placed to drive the development, standardisation and commercialisation of new technology. However, given the potential for significant benefits from the development of the IoT across a range of industry sectors, Ofcom is interested in views on whether it should be more proactive, for example, in identifying and making available key frequency bands, or in helping to drive technical standards.
The call for inputs closes at 5 pm on 1 October 2014. For a link to the relevant documentation, click here.
Article 29 Data Protection Working Party representatives meet with search engines on “right to be forgotten”.
Following the CJEU ruling in Google Spain (Case C-131/12), EU data protection authorities, united in the Article 29 Working Party, met with representatives of Google, Microsoft, and Yahoo! The objective of the meeting was to ask search engines about their practical implementation of the ruling, and to provide input to future Working Party guidelines. These guidelines will aim at ensuring a consistent handling of complaints by European data protection authorities facing requests lodged by individuals following delisting refusals by search engines. The guidelines will also frame the action of search engines ensuring the consistent and uniform implementation of the ruling.
The Working Party asked a series of questions during the meeting and the representatives of the three companies explained their views. The questions dealt mainly with the modalities of the delisting process (e.g. the scope of application of the ruling, the particular reasons for which there would be a preponderant interest of the general public in having access to the information, the notification of the delisting to third parties and the justification for refusal). The WP29 has also asked search engines to answer some questions in writing by the end of July.
Additional meetings may be organised in the future with other stakeholders. The Working Party guidelines are expected in the autumn. To read the Working Party press release in full, including the questions asked, click here.
Index on Censorship writes to Article 29 Data Protection Working Party over concerns with “right to be forgotten” ruling in Google Spain CJEU decision.
The letter states that, since the ruling was issued, Index on Censorship, an international freedom of expression charity, has “consistently and repeatedly” expressed reservations about the failure of the judgment to include recommendations for oversight mechanisms and provisions that would ensure freedom of expression and information rights, as well as obligations, are balanced with privacy rights. “We are disturbed both by the loose wording of the ruling and by recent comments from European information commissioners that appear to suggest that authorities are making a default presumption that – in the majority of cases – privacy rights trump those of free expression and right to information”, the letter states.
Index says that it is concerned that without the rapid introduction of uniform, Europe-wide guidelines from regulators on the implementation of, and oversight process for, all search engines implementing the “right to be forgotten”, the system will “lead to swathes of information that should be publicly available being hidden from sight”. This includes not just serious journalism but also information about, for example, individuals who use comment lines below articles as a form of harassment.
The letter calls on the Working Party, as a matter of urgency to issue detailed guidance on the types of information that can be considered “irrelevant” by search engines. In Index’s view, simply asking search engines to have a due regard to information that is “in the public interest” is insufficient guidance.
Index also calls on the Working Party for guidance on an appropriate mechanism of oversight to ensure that it is possible for data protection or other relevant national and European authorities to examine any search engines’ decision on a right to be forgotten request.
In addition, Index wants an appeals mechanism that allows publishers of content who have had links removed to be able to challenge that decision.
Essentially, Index is concerned that the recent CJEU decision and the actions of data protection authorities have failed to sufficiently taken into account freedom of expression. The charity urges greater consultation with civil society groups on the implementation of the Google Spain ruling and in the development of future data protection guidelines to ensure that freedom of expression rights are protected. To read the letter in full, click here.
Ofcom launches review of signing arrangements for relevant TV channels.
Ofcom is seeking views on whether the signing obligations applying to low audience channels should be reviewed for the first time since these were set in 2007.
A number of TV channels with an audience share between 0.05% and 1%, i.e. “relevant channels” are required by Ofcom to show TV programmes presented in sign language for viewers whose first language is British Sign Language.
As an alternative, since 2009, these TV channels may decide to contribute towards other arrangements, provided Ofcom is satisfied that these would make sign language programming available to deaf TV viewers. Around 50 channels, as an alternative, contribute money to the British Sign Language Broadcasting Trust, which pays for sign-presented content shown in the British Sign Language Zone on the Community Channel and Film 4.
The consultation asks whether the amount of signed programming on low audience channels should be increased, and if channels that choose to pay alternative contributions should increase the amount they pay over time. The consultation is open until 5 pm on 22 September 2014. For a link to the consultation documentation, click here.
Technology Innovation for Smart Publishing launches policy recommendations to boost innovation in book publishing and ICT.
The Technology Innovation for Smart Publishing, which is a European project coordinated by the Italian Publishers Association and which includes 25 organisations from 12 European countries, has released a set of policy recommendations, giving the publishing and technology sectors a common base at European level to foster and sustain innovation.
The document represents a common stance of both worlds regarding the essential actions needed to support innovation, and submits operational guidelines of industrial policy based on the needs of companies from both sectors.
The recommendations address policy makers looking to secure the smooth running of the markets concerned and the satisfaction of consumers, using existing instruments at their disposal. They call for more public investment, including research and development, and the allocation of project funding to support both sectors.
Recommendations range from fostering cooperation and mutual knowledge between the ICT and publishing sectors to enhancing digital skills, from facilitating access to research and finance to supporting initiatives that improve access to books by the visually impaired, as well as encouraging integrated ICT and publishing solutions to address commercial needs, increasing the discoverability of books online and creating more and more attractive products.
Marco Polillo, President of the Italian Publishers Association, coordinator of the TISP project said: “The TISP recommendations are an important outcome of the dialogue between two industries that converge in identifying common needs and provide realistic guidelines to European policy makers”. To read TISP’s press release in full, click here.
Advertising Standards Authority finds 888 Casino’s “£88 Free” ads misleading because winnings and withdrawals restrictions were not given sufficient prominence.
A poster stated “£88 Free No Deposit needed Slots. Blackjack. Roulette. Live casino”. Text at the bottom of the ad stated “18+ T’s & C’s (sic) apply”. The website www.888.com stated “Register at 888casino and you get £88 FreePlay*, no deposit needed!” The asterisk linked to further text at the bottom of the page which stated “* With the exception of a Jackpot win, max FreePlay winnings = £20 • FreePlay winnings must be wagered 30 times before withdrawal”.
The ASA upheld complaints that the ads were misleading finding that the poster did not make clear that winnings were restricted to a maximum of £20, and had to be wagered 30 times before any remaining balance could be withdrawn. The ASA also found that, although information regarding winnings and wagering requirements appeared in footnote text at the bottom of the website ad, the initial screen that consumers viewed simply stated, “Get £88 FREE” and invited them to register. The ASA was concerned that the offer was not given sufficient prominence and that a number of consumers could sign up for the offer without being aware of the restrictions that applied. As such the ads breached CAP Code rules 3.1 and 3.3 (Misleading advertising), 3.9 and 3.10 (Qualification), 3.23 (Free), 8.17 and 8.17.1 (Significant conditions for promotions). To read ASA Adjudication on Cassava Enterprises (Gibraltar) Ltd, 23 July 2014, click here.
European Commission and Member States take joint action on in-app purchases.
Following a large number of complaints in EU countries concerning in-app purchases in online games and in particular inadvertent purchases by children, national authorities have joined forces with the European Commission to find solutions.
The Commission says that coordinated enforcement action in the EU on in-app purchases in online and mobile games has made “real progress” in delivering tangible results. Industry has taken a number of measures that seek to address consumer concerns. It is hoped that action will increase consumer confidence in the fast-growing app sector.
A common position agreed by national authorities within the Consumer Protection Cooperation network and communicated to Apple, Google and the Interactive Software Federation of Europe in December 2013 asked that:
- games advertised as “free” should not mislead consumers about the true costs involved;
- games should not contain direct exhortation to children to buy items in a game or to persuade an adult to buy items for them;
- consumers should be adequately informed about the payment arrangements for purchases and should not be debited through default settings without consumers’ explicit consent; and
- traders should provide an email address so that consumers can contact them in case of queries or complaints.
Google has already decided on a number of changes. Implementation is underway and will be completed by the end of September 2014. These include not using the word “free” at all when games contain in-app purchases, developing targeted guidelines for its app developers to prevent direct exhortation to children as defined under EU law and time-framed measures to help monitor apparent breaches of EU consumer laws. It has also adapted its default settings, so that payments are authorised prior to every in-app purchase, unless the consumer actively chooses to modify these settings.
Member State enforcers and the Commission have also invited the associations of online game developers and platforms to reflect on concrete measures that they could take to address the issues raised in the common position, including the possibility for guidelines or standards.
Enforcement, including possible legal action, is in the hands of the national authorities, which will now consider how to address outstanding legal issues.
Advertising Standards Authority reminds competitors they must try to resolve complaints between them before involving the regulator.
The ASA published the reminder in the wake of its recent adjudication on a complaint made by Tata Global Beverages, who make Tetley tea, about a TV ad made by Unilever for its PG Tips “pyramid” tea bags. The ASA says the ruling involving the two tea industry giants “demonstrates the emphasis we place on advertisers being able to prove their claims as well as highlighting how careful competitors have to be to avoid denigrating their rivals”.
Tata Global Beverages challenged whether the ad misleadingly exaggerated the capability and performance of the pyramid tea bag and, by comparing and contrasting itself against round tea bags, denigrated Tetley and portrayed the brand in a negative light.
The ASA was, however, satisfied on this occasion that Unilever had proved its claims. Unilever provided test results that showed that the infusion of tea was greater when using a pyramid teabag than when using a round teabag. The ASA also concluded that the ad did not denigrate Tetley as the comparison was not made with an identifiable competitor.
In the light of its ruling the ASA clearly considered it necessary to emphasise that to avoid tit-for-tat complaints, advertisers must provide evidence that they have tried to resolve their complaints with their competitor before the ASA will agree to take on their case. To read Trouble brewing? Dealing with competitor complaints and for a link to the ASA Adjudication on Unilever UK Ltd (23 July 2014), click here.
Advertising Standards Authority updates complaint handling procedures.
The ASA’s complaint handling procedures are designed to ensure that complaints are processed in a way that is transparent, proportionate, targeted, evidence-based, consistent and accountable. To further these objectives the ASA has now incorporated its policy on restricting repetitive complainants; expanded its position on confidentiality; simplified the factors that may be taken into account when considering informal resolution; introduced a deadline by which requests to suspend publication of an adjudication must be made; clarified the steps the ASA and the Independent Reviewer might take to correct a perceived flaw in an adjudication; and explained the role the Communications team will play when dealing with enquiries about ongoing complaints. To read the ASA’s revised Non-broadcast Complaint Handling Procedures and Broadcast Complaint Handling Procedures click here and here.
Advertising Standards Authority finds Diageo’s “Captain Morgan” ad implied alcohol could overcome boredom and was capable of changing mood.
A picture posted by Captain Morgan on its Facebook page showed the pirate Captain Morgan raising a glass and cheering whilst surrounded by his crew. Text at the top of the image stated “WEDNESDAY. I’M DECLARING WAR ON MID-WEEK BOREDOM”. The ad was written in the same tone as a series of other regular posts on the Captain Morgan Facebook page which also promoted meeting with friends or the Wednesday mid-week milestone, including one that stated “Gather your crew” and another which stated “Navigate through hump day and set your sights on the weekend!”.
Following a complaint from the Youth Alcohol Advertising Council (YAAC) that the ad was irresponsible, the ASA found that most consumers would interpret the ad to mean that the Captain was alleviating his boredom by drinking with friends. The ASA considered that consumers were unlikely to view other posts on the page relating to meeting with friends or the “mid-week” milestone as related or as part of a series and concluded that their presence was unlikely to change a consumer’s impression of the ad in question. Similarly, the ASA considered that the presence of “drink responsibly” posts did not undermine the fact that the ad, although not expressly encouraging excessive drinking, implied that the Captain had sought alcohol to improve his mood. As such, the ASA concluded that the ad breached CAP Code rules 1.3 (Responsible advertising), 18.6 and 18.7 (Alcohol). To read ASA Adjudication on Diageo Great Britain Ltd, 23 July 2014, click here.
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