I’ve finally got around to replying to RTÉ regarding the alcohol adverts on their home page in September. There are so many things I have to say to RTÉ that I found it hard to know where to start. Here’s the homepage in question:
First I asked RTÉ about their online advertising guidelines and they responded. You can read about this in my older blog entries.
Anyway, here’s my response. I’ve also decided to complain to the ASAI. I know it could be argued that RTÉ are in compliance and my complaint will not be upheld, I don’t think that the guidelines for RTÉ.ie are clear enough and seem contradictory in parts. I’ll report what happens.
There are certainly plenty of guidelines to be followed! It must be difficult to decide which take precedence. It might have been a good idea for you to send me link to them so that I could take a look and not waste your time. Thankfully the ASAI have helped and have pointed me in the right direction.
I can’t help noticing your job title and was surprised to receive a response from a Sales Manager. Surely as a Sales Manager, your role is to sell and to make as much money as possible for your employer, pushing the guidelines and boundaries as much as you can. I’m sure it’s also part of your role to sell responsibly of course, really I don’t mean to offend but, you are probably not the best judge regarding compliance. Isn’t there an internal department for this kind of thing? Should you not have provided links me toward all of the information I needed in your email and possibly also pointed me in the direction of who to complain to if I wish to take the matter further.
Your response, whilst very welcome, makes me think that maybe there should be a better internal procedure to deal with queries like my own. My original query (as that’s what it was, a query and not a complaint) was sent in the first instance to: firstname.lastname@example.org as suggested on RTÉ.ie. I never did receive a reply or an acknowledgment of that email even though 2 weeks elapsed before resending my query as a complaint. I must say was really impressed by the updates I received once I had ‘complained’ and was therefore ‘in the system’.
You mention that you believe RTÉ are in compliance in relation to my query. Of course, you would say that, (you are RTÉ!) seriously though, that’s great. I do have a few points I wish to raise if you could take a moment to consider them I’d be very grateful:
1. You said “…for example, no advertising is carried across children’s websites or children’s programmes on the RTÉ player.”
That’s great to hear. I’m assuming that the children’s web sites referred to are:
I don’t think we can just assume that children are totally protected from advertising because of this. It would be interesting to know how many users arrive at those sections of RTE.ie by typing in the URLs above and how many navigate to the correct area via the RTÉ.ie home page which is were the alcohol adverts I object to were. I suspect a large percentage of users type in RTE.ie and take it from there. Why else would you have links to the children’s sites on the RTÉ.ie home page?
Also, the web sites in question all have tabs at the top, the first of which is a link to the RTÉ.ie home page and the alcohol adverts. If you are expecting children to navigate between children’s sites by using these tabs, you are also expecting them to navigate to the RTÉ.ie home page.
2. I note that “ …alcohol advertising/marketing is not permitted unless the relevant medium has an adult audience profile of 75% or greater.”
I’ve looked at your ABC figures and from those it would seem that there are no children accessing the RTÉ.ie at all. This is not really a surprise as under 15s can’t be counted in these figures anyway. This clearly can’t be the case otherwise why would you bother creating sections on RTÉ.ie specifically for children at all?
It’s easy to cherry-pick sections from guidelines. Maybe as you say, certain instances are stricter regarding alcohol advertising online but it seems to me that there are also other instances where they are not.
“ Family ‘breakfast’ TV time (6am -10am) will be treated as children’s viewing time and will not carry any alcohol advertising.”
(from Television, pg. 8, point 4 of the Code of Practice for Alcohol Advertising)
The alcohol ads on RTE.ie were certainly present during that time.
I draw also your attention to another paragraph in the same section:
“Where alcohol advertising is permissible under audience profiling a maximum of 25% of sold advertising time and only one in four advertisements for alcohol products is permissible across the broadcast day excluding the period from 6 a.m. to 10 a.m. Additionally no more than twoadvertisements for alcohol products can appear in any commercial break. The full provisions of this clause are specifically intended to apply to the peak viewing periods from 6pm to 11.30pm.”
(from Television, pg. 8, point 2 of the Code of Practice for Alcohol Advertising)
At the time in question 4 out of 6 adverts on your home page where for alcohol and this seemed to be the situation 24 hrs a day.
Also, I wonder, if animated ads (as the alcohol ads in question were) should be treated differently from static ads?
3. I quote RTÉ’s own Programme Standards and Guidelines which state on page 88 (under the heading “RTÉ’s Online Services”):
“The same standards which apply to RTÉ’s services on radio and television also apply to RTÉ Online.”
And further down:
“Awareness that children may access websites without parental supervision must be taken into account at all times by those with editorial responsibility for the contents of RTÉ Online.”
I’m aware that the key word above is ‘editorial’ responsibility but clearly on TV it’s easier to tell the difference between advertising and editorial. The difference is not so clear cut online. It’s my opinion that there should not be a difference between advertising and editorial responsibility especially when your own guidelines as quoted above state that children may be accessing RTÉ.ie unsupervised.
I’m glad to see that there has not been a re-occurrence of the same amount of alcohol advertising since the occasion in question… just the odd ad here and there. I do notice though that there are plenty of ads for gambling. Are there separate guidelines to cover those? Maybe there should be a separate code for your online presence seeing as ads are viewed along with and not separate from editorial content?
As I’ve said before on my blog: I still think that the ads reflect badly on our ‘National Broadcaster’. It’s not a great image for Ireland and for many outside the country, the RTÉ.ie homepage is, in a way, our shop window.
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