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Bulletin: 18/3
Batch: 250
Reference: 30643
Product: Business (Pharmacy)
Advertiser: Boots, Faces By Grace
Influencer:
Agency:
Medium: Internet (Social Media)
ASAI Code 7th Edition: 2.4(c), 3.31, 3.32
An Instagram post by Faces by Grace referred to the following:
"NEW POST!!!ANYONE ELSE FORGET THEIR BOOTS ADVANTAGE CARD WHEN SHOPPING? NOW YOU WILL NEVER MISS OUT ON POINTS!
COMMENT ON MY LATEST PICTURE AND LET ME KNOW WHAT YOU BUY MOST
OFTEN IN BOOTS!”
Beneath the above text an image of a baby’s feet appeared. This image was accompanied by the text “Tiny toes” and an emoji with heart shaped eyes and a smiley face
Viewers were then invited to:
“Swipe up to download the app. See More”.
The complainant considered that it was clear from the post that the Influencer was working for Boots Ireland and expressed concern that the post had not been hash tagged accordingly with #sp.
The advertisers’ said that their PR Agency had contracted the Influencer for a paid engagement to promote the launch of their Digital Advantage card across Instagram.
They said when the activity was to go live, it was to include two bursts of activity.
- Activity 1: How to download and use the Digital Advantage Card
- Activity 2: The Influencer’s personal favourite ‘points picks’ – her favourite Boots purchases and the points earned for each.The advertisers said before the posts went live their PR agency had provided a briefing document to the Influencer. This included the detail of the promotion, and also a request for the inclusion of #sp or #ad on all posts. They said a link to the ASAI Guidelines had also been provided to the Influencer at that point in time.
They said further to the briefing document, the PR agency had a briefing call with the Influencer and her agent to discuss the document and clarify any outstanding queries.
For activity one, the Influencer had sent through all posts for approval. These were approved by both the PR agency and Boots Ireland. There had been seven Instagram story posts in total and one Instagram static post in this activity. During the review process, these had not contained the relevant #ad or #sp referencing, but relevant referencing was to be added by the Influencer before the content went live. The Instagram static post had featured the correct referencing, but only six of the seven Instagram story posts had contained the required #ad or #sp references. Therefore, one Instagram story post had gone live without the relevant #ad or #sp reference and this is what had resulted in the complaint being made to the ASAI.
The advertisers said, in future, their PR agency would ask for sight of all posts which require #sp or #ad before they go live. They said their agency would also ensure that the posts were clearly marked and in a legible font size and colour to ensure clarity of all sponsored content in the future.
The Influencer said it had been a mistake in forgetting to use the hashtag, it had been a case of human error and she apologised for any confusion caused.
Complaint Upheld.
The Complaints Committee considered the detail of the complaint and the responses received. The Committee noted that of the seven Instagram story posts, one had not been hash tagged appropriately to indicate that it was a marketing communication. In the circumstances the Committee considered that this story post was in breach of Sections 3.31 and 3.32 of the Code.
ACTION REQUIRED:
The advertisement should not appear again in its current form.The Committee acknowledged the steps being taken by the advertisers to ensure compliance with the Code. They reiterated the importance of ensuring that all marketing communications were recognisable as such, for example, that all relevant social media posts had appropriate hash tags.