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Advertiser: Universal Pictures International Ireland
ASAI Code 7th Edition: 2.4(c), 3.3, 3.23, 7.2, 7.4
Two versions of an advertisement for the film ‘Halloween’ were screened on Virgin Media channels before 21:00.
Advertisement 1 – Appeared at 20:34
The full-length advertisement depicts the character Michael Myers wearing a mask and wielding a knife in various scenes, a woman screaming while trapped in a bathroom stall as Michael Myers attempts to break down the door and a character preparing to use a shotgun in a ‘cat and mouse’ style scene as the following lines of dialogue are heard:
“Michael Myers spent the last forty years in captivity.”
“I prayed that he would escape…so I can kill him.”
Advertisement 2 – Appeared at 20:28
The shorter countdown advertisement shows a young boy in bed while his babysitter sits beside him. He asks her to close the closet door and she attempts to. However, something blocks it from closing fully and she tries again to no avail. She opens the door and Michael Myers is standing in the closet. He raises a knife and brings it down into the babysitter while the film title is displayed followed by
“15 days to go”.
Two complaints were received in relation to these advertisements.
Both complainants felt the scenes shown during the advertisements were unsuitable to have been broadcast at the times in question during what they considered to be family programming. They both said that their children had been watching television at the time the advertisements were broadcast and one complainant said that her child was extremely upset and affected by the advertisements.
The advertisers said that they had taken all reasonable and required measures to ensure that the content was cleared for, and broadcast at, appropriate times so as to reach its intended adult audience. They believed the advertisements were not unduly shocking or distressing for the intended audience of 18 years and over and therefore did not believe the advertisements to be in breach of the Code.
They advised the film was rated ‘18’ by the Irish Film Classification Office and said there were three versions of the advertisement created:
- A full length (20s) advertisement (the Full Ad)
- A short (10s) advertisement (the Night Countdown Ad) counting down the days to cinema release (suitable for evening broadcast during non-family programming) created by cutting down the Full Ad.
- A short (10s) advertisement (the Day Countdown Ad) counting down the days to cinema release (suitable for daytime broadcast during non-family programming) created by cutting down the Full Ad.
They said they acknowledged that in order to convey the theme and storyline of the film, both the Full Ad and the Night Countdown Ad contained material that would not be suitable to be targeted at children.
They said the Full Ad was submitted to Clearcast (1) in order to identify any broadcast restrictions. The Full Ad was given a post-21:00 restriction and this information was provided to the broadcasting stations accordingly.
They further said, however, that Virgin Media were not obliged to follow Clearcast restrictions and that they cleared material independently for broadcast on their channels. Therefore, neither Countdown Ad was required to be submitted to Clearcast. Virgin Media gave both the Full Ad and the Night Countdown Ad a post-19:00 restriction, with no restriction placed on the Day Countdown Ad.
The advertisers said that all of the advertisements were targeted at an adult viewership. They requested that its media-buying agency targeted all ads at the audience segment ‘All Adults, 18+’. This dictated that the advertisements were not broadcast during programmes considered to be family-oriented or targeted at children.
They reviewed the broadcast schedules for the advertisements and endeavoured to identify which advertisement each complaint related to. They were unable to identify exactly which programme the first complainant referred to due to the approximate timeframe provided in their complaint, however they confirmed that the complainant would have seen either the Night Countdown Ad during Coronation Street at 20:45 on Virgin Media 1 or the Full Ad during a UEFA Champions League Match at 20:34 on Virgin Media 3. They said that due to the nature of its storylines, Coronation Street was not considered to be family-oriented programming. They said that due to the audience viewership of UEFA Champions League, this was also not considered to be family-oriented programming. They therefore considered that the advertisement was responsibly targeted in both cases.
They confirmed that in the case of the second complaint, the Night Countdown Ad was broadcast at 19:10 during Emmerdale. They again advised that due to the nature of its storylines it would not be considered family-oriented programming and they therefore believed the advertisement was responsibly targeted.
(1) Clearcast is a non-governmental organisation which pre-approves most British television advertising
The Complaints Committee considered the detail of the complaint and the advertisers’ response. They acknowledged that the advertisers had made efforts to ensure the advertisement was targeted at adults and they accepted that the advertisements had not been shown during children-oriented programming. The Committee also noted that the programming, where the advertising had been seen, was not considered ‘family viewing’.
They were concerned, however, that the content of the advertising containing scenes from the movie, which was an 18s certified movie, was likely to frighten and disturb young viewers. The Committee considered that given the nature of the content and the likelihood of young viewers observing or viewing television up to 21:00, the advertising should not have appeared pre-21:00 and that it was in breach of Sections 7.2 and 7.4 of the Code.
The advertisement must not reappear in its current form.