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Product: Food & Non-Alcoholic Beverages
Medium: Digital Media - Social Media
ASAI Code 7th Edition: 8.18
A Facebook post that appeared on the advertisers’ own account and as an advertisement, included a video featuring teenagers wearing their school uniform hanging out at a park while eating McDonalds.
The post was captioned with the following:
“Mates and a McDonald’s. Does it get any better?”
The video included the following wording:
“Fancy just being yourself?
Fancy a McDonald’s?”
The advertisers’ Facebook page had five buttons at the top which remained visible when scrolling. These were Use app, Like, Message, Search and three dots.
Two complaints were received regarding the advertisement, one from a consumer and the other from the Irish Heart Foundation. Both complainants objected to the advertisement on the following grounds:
The complainants considered that the advertising was encouraging viewers to purchase McDonald’s within the app.
The complainants considered that the post was targeting young people as it was linking the app to the post and showing young school friends enjoying themselves.
The complainants considered that the advertising was condoning eating ‘junk food’ outside of family mealtimes.
The complainants considered that the advertisement was giving the impression that eating McDonald’s with your friends would help your social life.
The advertisers stated that they were, at all times, concerned to ensure that the manner and form of their marketing communications complied with the requirements set out in the ASAI Code. They said that they took their obligations in relation to marketing communications addressed to children very seriously and did not, therefore, target their advertisements on Facebook to users under the age of sixteen. While they did not consider that their advertisement was in breach of the Code, in order to avoid any future confusion as to the intended audience of the marketing communication, they did not intend to run the advertisement again.
They responded to the complaint issues as follows:
The advertisers stated that the advertisement/video did not refer to the McDonald’s mobile application (App), nor did it direct customers to use or download their App in order to purchase McDonald’s products. They said that it was not possible to purchase food products on the version of their App that was currently available in Ireland.
The advertisers stated that, as a matter of general policy, they did not address any marketing communications to children via social media. In relation to Facebook in particular, where they place advertisements using the ‘Facebook Business Manager’ (the tool for booking advertisements on Facebook), the custom audience was always set to ages sixteen to forty-four which meant that their advertisements on Facebook were only delivered to Facebook users who, according to the age details they have included in their Facebook profiles, were over the age of sixteen and were not served to any Facebook users whose account details indicate they are under the age of sixteen.
They sourced the booking data for the ‘Fancy Just Being Yourself’ advertisement which confirmed that 97% of the impressions (an impression is the instance when an advertisement is on screen for the first time) for the ‘Fancy Just Being Yourself’ advertisement was delivered to Facebook users over the age of eighteen. They said that only 3% of the impressions were delivered to Facebook users between the ages of sixteen and eighteen and none of the impressions were delivered to Facebook users under the age of sixteen.
In regard to the appearance of the post on their own Facebook account, the advertisers stated that over 99.7% of their Facebook Fans, i.e. those who “like” the McDonald’s Facebook page, were aged 18+ which they verified through Facebook Analytics and provided a copy to the Executive.
In regard to the portrayal of school friends, the advertisers stated that the advertisement portrayed a group of young people having fun and enjoying eating McDonald’s food products together and was intended to demonstrate that eating McDonald’s food products with friends was an enjoyable social experience.
The advertisers stated that none of the individuals featured in the advertisement were shown engaging in excessive consumption or any other unhealthy or unbalanced eating habits. They said that the advertisement was not an advertisement for High Fat Salt and Sugar (HFSS) food products as neither of the products featured, medium fries and a chicken McNugget share box, were HFSS foods when applying the nutrient profiling model.
The advertisers stated that the advertisement portrayed a group of young people having fun and enjoying eating McDonald’s food products together. As indicated in the caption (“Mates and a McDonald’s. Does it get any better?”), they said that the advertisement was intended to demonstrate that eating McDonald’s food products with friends was an enjoyable social experience. They said that the advertisement was not intended to imply that the benefits of eating McDonald’s food products included a wider group of friends or increased social activity, nor did they think that the average viewer would interpret the advertisement as suggesting that eating McDonald’s food products would “help their social life”.
Issues 1, 2, 3 and 4 – Not Upheld
The Complaints Committee considered the detail of the complaint and the advertisers’ response.
The Complaints Committee noted that the Use app button was not linked to or from the video advertisement. They also noted that no reference was made in the video advertisement to the App, and further noted that it was not possible to directly purchase product from within the App.
The Committee noted that the young people featured in the advertisement were enjoying themselves but did not consider that the advertisement implied that this was because they were consuming the advertisers’ products. The Committee noted that the products were not classed as HFSS product, and that the advertisement did not depict immoderate or over consumption. The Committee also noted that the complaints had referred to ‘family eating time’ but considered that there was no indication of the time of consumption, and that the Code did not require food consumption to only be shown at certain times or settings.
In the circumstances the Complaints Committee did not consider that the advertising was in breach of the Code on the grounds suggested in the complaint.
No further action required.