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Product: Health and Beauty
Advertiser: Coty (Rimmel Ireland) and Rosie Connolly
Medium: Social Media (Facebook and Instagram)
ASAI Code 7th Edition: 2.4(c), 4.1, 4.4, 4.9, 4.10
Advertisement 1: Facebook (Rimmel Ireland)
The advertising on Rimmel’s Facebook account featuring an image of Rosie Connolly, fashion, beauty and lifestyle blogger, referred to the following:
“The stunning RosieConnolly.ie putting our NEW Lasting Finish Breathable foundation and concealer to the test! Long-lasting makeup with an ultra-light and flawless coverage that lets your skin BREATHE. Have you tried it yet? #RimmelLondon #LastingFinishBreathable #LiveTheLondonLook”
Advertisement 2: Rosie Connolly Instagram:
Rosie Connolly’s Instagram post featuring the same image referred to the following:
“rosieconxxx Paid partnership with rim…
Trying out the new @rimmellondonire Lasting Finish Breathable 25 hour foundation and concealer today! This foundation has such a stunning finish and is super affordable, as well as having an anti-oxidant formula which is great for problem skin. Head to my Snapchat or Insta story to see how I applied it, and how it lasted all day. Great for being on the go, and a 10/10 from me. #FreeYourSkin #Rimmel #LiveTheLondonLook #adHealth.”
The complainant considered the advertising to be misleading. She said the image of Rosie Connolly’s face had been filtered and photo shopped. She considered that people may purchase the Rimmel Foundation thinking they would achieve the same results if they used the product but as the image had been altered this would not be the case.
Ms. Connolly said that Rimmel had approved the images which she had forwarded to them, therefore, the complaint should be addressed to them.
The advertisers said the post was not intended to mislead and they had removed it because it did not reflect their values as a brand. They said they had explicit guidelines in place in keeping with the guidelines set out in the Code. They acknowledged that the image in the posts had been filtered using an in-built camera feature. They said while this specific practice was not addressed in the ASAI guidelines, they had taken the following steps to avoid any future issue with heavily filtered images/content:
• Their policy will be made even more explicit to require any use of filters/photo shopping by any influencer to be flagged and details provided. If there are any post-production techniques used, they will be declared and transparent and any disclaimer will be clearly visible in the materials.
• They will stringently monitor all paid posts to ensure all activity meets their new guidelines.
• They have taken steps to remove the post from all media and insisted that Ms. Connolly do the same to the extent which she is able.
In conclusion the advertisers said they were a recognised leader in global beauty and took their customer satisfaction and regulatory compliance very seriously. They said any complaint which they receive causes them concern as they fully believed in their products’ effectiveness and value to their customers. Going forward they said they will ensure that any paid content from influencers will reflect this.
The Complaints Committee considered the detail of the complaint and both the advertisers’ and the bloggers’ response.
The Committee noted that camera filters were one form of post-production techniques that could be used in the creation of material for social media posts. They referred to the Code requirements that advertising should not mislead (Section 4.1), should not exploit consumers credulity, inexperience or lack of knowledge (4.4) and that claims that consumer could be likely to regard as objectively true should not be made unless they could be substantiated (Section 4.9).
The Committee considered that the use of post-production techniques which exaggerated the effects of an advertised product could mislead and they welcomed the steps the advertisers had taken in removing the posts. They considered, however, that the advertising had been likely to mislead and was in breach of Section 4.1, 4.4 and 4.9 of the Code.
As the posts in question had been removed no further action was required in this case.
The Committee reminded all involved in the production of marketing communications that care should be taken so that the use of pre- and post-production techniques did not mislead about the attributes of the product being advertised. They considered in addition, that whilst disclaimers as to the use of such techniques could mitigate the extent to which the advertisement was likely to mislead, care was needed as even with disclaimers the overall effect of the advertisement could be that it misleadingly implied a product claim when such a claim could not be substantiated.