Blog from the Bog

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.

Dear xxxxx,

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: onlineproduction@rte.ie 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:

http://www.rte.ie/tv/theden/
http://www.rte.ie/tv/twotube/
http://www.rte.ie/tv/dentots/
http://www.rte.ie/tv/red/

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.

For example:

“ 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.

Life in Currane RTÉ, TV

I do still have things to say about RTÉ.ie and alcohol advertising. I just don’t know where to start! I was happy to get a response but I’m left feeling quite deflated and annoyed by it. Will have a go soon.

Meanwhile, we’re trying to get the house as watertight as possible for the winter. The days are really starting to shorten now. The chickens are doing well. Of this year’s chicks, it’s clear now that Bruno is definitely a boy and that Janet probably is also. Hopefully Latoya and Tito are girls. It’s early days for Tito still.

We have huge changes to the site coming soon. List item numbering will be ‘rolled out’ (as Al would say) across the site soon. Numbering will mean that items can be inserted into a particular place in a list. You’ll also be able to make list items (or just selected text), bold or italic or ‘tada’…. a link!

The picture above was taken on one of our last summery days (Note: Trudi’s head).

Life in Currane Al, chickens, chicks, Corraun House, Lifelisters, Lifelisting, Lifelists, mylifelists.com, RTÉ, techie stuff, Trudi, TV

I’ve had a response, here it is*:

(*I’ve chopped off the first line which was nice and friendly and the last line which includes the name and job title of the person who responded)

Many thanks for your enquiry.

In relation to advertising guidelines, RTÉ adheres to both guidelines from ASAI, The Alcohol Monitoring Bureau, the BCI and  its own internal Guidelines.

The guidelines listed above are directed primarily at broadcast and where possible, emulated across online properties, however in certain instances are
stricter – for example, no advertising is carried across children’s websites or children’s programmes on the RTÉ player.

Specifically with respect to your query relating to alcohol advertising, rté.ie does carry alcohol advertising in accordance with industry guidelines and our own internal guidelines.

I have attached an excerpt below from the Alcohol, Marketing, Communications and Sponsorship Codes of Practice, for your information:

‘The Codes herein are based on the principle of audience profiling across all media and sponsorships
whereby alcohol advertising/marketing is not permitted unless the relevant
medium has an adult audience profile of 75% or greater.

In addition, where alcohol advertising is permissible under audience profiling a weight ceiling will
apply across all media and sponsorships whereby alcohol advertising will be limited to no more
than 25% of available space on any occasion’

I can confirm that we are in compliance in relation to your query.

Kind Regards,

Not a bad email really. I’m going to let it sink in, over the weekend, before I say anything.

Life in Currane RTÉ, TV

Impressive response from RTÉ. One of the new email addresses I tried, seems to have got me through to the right people and they clearly have a procedure for dealing with questions like mine. The status of my query has been updated several times today. I expect a response soon

Meanwhile, I’m still not happy with the 75% adult thing. I feel very uncomfortable about it. You see, referring back to ‘The definitive version of RTÉ Programme Standards and Guidelines’ as mentioned in part 2:

“The same standards which apply to RTÉ’s services on radio and television also apply to RTÉ Online.”

As well as the 75% rule, the Alcohol Marketing, Communications and Sponsorship Codes of Practice. states under the Television 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 two
advertisements 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.

and also:

Family ‘breakfast’ TV time (6am -10am) will be treated as children’s viewing time and will not carry
any alcohol advertising.

The adverts I’m concerned about, were visible for at least 72 consecutive hours including during “Family ‘breakfast’ TV time”.

Life in Currane RTÉ, TV

Although the ASAI originally told me that they are responsible for content of advertising only (see part 3). They’ve been very helpful and after further discussion have explained to me that there is however another code called the Alcohol Marketing, Communications and Sponsorship Codes of Practice. This code was initiated by the Minister for Health and Children in 2002. The ASAI  have been asked by the Department of Health to examine complaints received regarding complaints made under these Codes.

According to page 18, point 1:

Advertising for alcohol should only be booked by an alcoholic drinks advertiser or its agency or placed by the media owner on any website with an adult audience profile of 75% or greater. Where a profile is not available every reasonable effort should be made to ensure that it is not aimed at young people.

I’ve taken a look the RTÉ.ie ABC report for May 2009 – it’s the only one I could find a link to on the RTÉ site. According to that report, only 2.1% of users are under 18. Clearly the figures are very low (I do feel that under 18s are very unlikely to fill in an online survey) but even so I seems like the guidelines are being followed. They are split as follows; 16-17 years – 1.5%, 15 years – 0.6% and under 15 – 0%. I thought it was a little odd that there are 0 under 15s looking at the site until I discovered that: “The Visitor profile data stated is for ROI (Republic of Ireland) respondents 15+years only….” So under 15s aren’t counted at all. Maybe they wouldn’t tell the truth anyway. Maybe they are counted, but are making themselves older. How would we know.

I accept that guidelines are being followed in that regard, but personally, 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 homepage is, in a way, our shop window.

Meanwhile, I’ve sent some more emails different RTÉ addresses as I’ve had no reply so far.

Life in Currane RTÉ, TV

I’m still awaiting a response from RTÉ. Here’s a reminder of what I’m getting het up about and remember, it was visible for at least 72 hrs, night and day.

Meanwhile, I recieved an email from  the ASAI (Advertising Standards Authority for Ireland) today:

….”The Code of Standards for Advertising, Promotional and Direct Marketing in Ireland generally refers to all media including, since August of this year, advertising on websites.  Our Code, however, deals with the content of advertising only.  Media owners may have their own guidelines on type of advertising they accept and is a matter for each media owner.   In the circumstances RTE should be able to assist you in your enquiry.”…

I had suspected that this might be the case. It’s beginning to seem like RTÉ don’t have to answer to anyone but themselves.

Life in Currane RTÉ, TV

Thanks to those of you who replied to me about RTÉ. I don’t normally get many comments on this blog because so very few people know it’s here. Your responses have got me thinking and it’s great to know that It’s NOT just me!

On September 4th I emailed RTÉ, this is what I said:

“Hello, I’m interested to know what kind of guidelines you have to adhere to regarding advertising on the RTÉ web site. Can you advise? I’m left wondering because personally, I’ve felt that the sheer amount of Bulmers ads on your home page this week has been too much. Maybe I’m overreacting but I don’t know the rules. It seems that that’s a lot of booze advertising for the daytime users.
Here’s a link to my blog where I mention my concern: http://www.mylifelists.com/blogs/
Thanks.
Jane”

I sent this email to the ‘onlineproduction’ email address as recommended on the RTÉ  web site (as this is  a query about the web site). As of today, I’ve had no reply.

I’ve taken a good look at the documents on the RTÉ site including ‘The definitive version of RTÉ Programme Standards and Guidelines’. On page 87, under the heading ‘RTÉ’s Online Services’ it says:

“The same standards which apply to RTÉ’s services on radio and television also apply to RTÉ Online.”

Further on in that section:

“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.” (Note ‘editorial responsibility’).

Regarding Advertsing (Page 82):

“There are guidelines on advertising, children and broadcasting, product placement and sponsorship which must be observed.”

I’ve not been able to find out what the guidelines are. I’d love to look at them to see what they say about alcohol advertising.

On September 4th I also emailed the BCC (Broadcasting Complaints Commission) to ask what guidelines have to be met. I received a reply on September 7th:

….”Although the RTE website does fall within the remit of the BCC, this is only with regard to news and current affairs.”

and

“In relation to your complaint, you are required to contact RTE directly. You may wish to send your concerns to complaints@rte.ie.”

The thing is, I don’t actually know if I have a complaint (although I suspect I do), I just want to know what the guidelines are.

The BCC suggested I contact the ASAI (Advertising Standards Authority for Ireland). I’ve done this today. I’ve asked them about guidelines. I didn’t do this in the first instance because from what I can make out, the ASAI deal mainly with the suitability of an advert and not so much with when and where it is shown.

Well, I’ve got a little bee in my bonnet now, I’ll keep you posted when (if) something happens.

Life in Currane RTÉ, TV

Here’s the front page of the National Broadcaster RTÉ’s website, as it has been for the past few days.

RTÉ web site front page.

Is it just me that finds all of this alcohol advertising a bit too much. Am I turning into an old fuddy-duddy? All of the 4 cider ads you can see are animated. Click to enlarge image.

Life in Currane moaning, RTÉ, TV

The wonderful Tony Hart has died. He was such an inspiration when I was a child and a big part of the reason I studied Art & Design.

He was however also the source of one of my biggest childhood disappointments. My picture of ‘Sunset with Birds’ (executed in felt tips) was never chosen for the Vision On Gallery. I was so confident that it would be shown that I suspected foul play when it wasn’t. First I blamed the Post Office, then the BBC.

It seems that I’ve reached the age when this type of thing will be happening more and more frequently. Oliver Postgate, another big part of my childhood died in December.

Life in Currane art, beauty, creativity, escapism, favourite things, happiness, ideas, inspirations, TV

Series 5 of the Wire starts tonight at 10pm on FX. I’ve been looking forward to it since the end of series 4. At the same time it will be hard knowing it’s the last series. Over the last few months we’ve watched the whole thing from the beginning finishing with the 3 final episodes of season 4 last night.
Dragon’s Den starts again tonight. It’s not The Apprentice but it’ll do. For the next few weeks, Monday night will be a big TV night for me.

Life in Currane favourite things, inspirations, The Apprentice, The Wire, TV