The Advertising Standards Authority : Part I

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 ASA ad thumbnail Two Advertising Association Ads

Ad for Peugeot 206 emphasising (aggressive) speed ASA Top 10 complaints booklet thumbnailA couple of banned ads for the Peugeot 206


Accurate or Misleading?

ASA announcement about proper advertising.Here is a typical ad for the Advertising Standards Authority.  It promotes the ASA as a professional body intent on upholding advertising standards. At the same time it encourages participation by the consumer in helping uphold these standards. 

How high these standards actually are, in some respects, you can judge after you have considered the correspondence below and the various semi-subliminal and manipulative ads illustrated throughout this Web site.  

Bear in mind that, as a profession, advertisers feel free to make use of any techniques that the public accept and only concede ground in the face of public and political pressure and the likelihood that they will be subject to government legislation. 

The ASA, in fact, evolved because of the desire of advertising professionals to avoid compulsory legislation, not through any inherent desire on the part of advertising professionals to limit their techniques to those which consumers would find acceptable. The ASA ads you see in this section and elsewhere on this Web site thus make a virtue out of what is a necessity.   Whilst the ASA operates in the interests of the consumer, one should also bear in mind that the ASA Code of Advertising is an instrument for the advertising profession and largely managed by advertising profesionals. 

There are clearly ads many ads which the public would find unacceptable. Yet not all of them are open to scrutiny, as this Web site indicates.   Yet many of these are tacitlyASA announcement about withdrawing improper advertising approved by the ASA.   Tobacco ads, for example, are vetted in deference to public concerns. But the vetting is only in terms of concepts, not in terms of how they will actually be presented to the public in newspapers, magazines or on billboards.  Ideas acceptable on paper may thus metamorphose into something less acceptable. Yet, even if those ads ultimately deemed unacceptable were viewed in their final stages of development, prior to publication, it is debatable whether any of those who could scrutinize them  would note the semi-subliminal elements.  

Even if they did, it is unlikely that anything would be done about them - as the correspondence reproduced on Part II of this page indicates.   This negative view is also supported by a careful reading of the Code of Advertising. There it is evident that manipulative, semi-subliminal, advertising does not fall under the remit of the ASA.    Yet, if the ASA exists to protect the consumer from unethical advertising, to ensure that ads are 'open and above board', then manipulative advertising surely ought to be one of their concerns. 

The only arguments in favour of ignoring semi-subliminal advertising are the traditional arguments initially noted on the Ads from the Archives page i.e. that such advertising (usually erroneously labelled subliminal advertising) does not exist, and, if it does, it is ineffective.

There is uncertainty in academic circles as to whether or not semi-subliminal advertising is influential.   However, there has been insufficient research in this field for one to pay too much attention to the statements of most commentators and researchers.  On the other hand, advertising agencies and their major clients have assiduously used this type of technique for at least a decade. If the relevant ad agencies and their clients do not yet know whether semi-subliminal advertising is effective then the entire populations of the USA and the UK are the guinea pigs in their ongoing 'studies'.

Given the extensive usage of semi-subliminal elements in cigarette advertising, there is undoubtedly a mass of data in the archives of tobacco companies, if not in those of advertising and marketing departments of major ad agencies and other client companies. Disclosure of this information would leave consumers in no doubt as to whether or not manipulative advertising of the sort illustrated on this Web site influences people without their being aware of the influences.

The denials that emanate from agencies such as the ASA, IPA and AAAA are either uninformed or misleading. It is time for the advertising agencies and their clients to come clean about their attempts at manipulation or acknowledge that some agencies, at least, make use of unethical techniques. And for organisations such as the ASA to become less of self serving bodies, whose interests would primarily seem to be ensuring that legislation does not cramp the style of advertising professionals, rather than serving the interests of the consumer and society in general.

Such goals might seem to be too much too ask. However, if they are, why are they already enshrined in principle in the Standards of Practice of the ASA, AAAA and other bodies. Guidelines, of course, need to be backed up with penalties if the public - and members of the profession - are to be convinced that they should be taken seriously. Will action be taken in the light of the examples presented later on this page and elsewhere on this site? Only the future will tell.


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Right or Partly Right?

Peugeot 206 ad emphasising speed. Embedded skull and faces.This is an example of an ad that was recently withdrawn from circulation because it breached ASA guidelines regarding the promotion of cars on the basis of speed.  

So far, so good.  However, this ad did not simply promote excessively speedy driving, it also promoted aggressive driving.   This aspect of the ad was completely overlooked by the ASA, yet it is probable that the semi-subliminal content helped convince the ASA members that this otherwise innocuous ad was unacceptable, just as it was intended to influence susceptible viewers of the ad. 

View the 'splash' on the left hand side of the ad.   Seemingly 'here one moment and gone the next', states the caption.   The car that produced the 'splash' has disappeared from the scene. However, what has not gone are the semi-subliminal 'faces' incorporated into the 'splash'.   As may be perceived in the full sizeextract from Peugeot ad with rollover. excerpt on the right, there is one major 'face' and a number of subsidiary 'faces' embedded in the splash.  Two of these 'faces' are circled, one on the rollover image looking left, the other on the illustration below looking diagonally left.

Some of these faces may be perceived as aggressive in nature, emphasizing the fact that excessive speed is usually ssociated with aggressive, bumper to bumper, driving. These screen images are of relatively low resolution compared to the original printed ad. Viewers who are unable to discern the 'faces' here may need to find a copy of the original ad or await the availability of CD's containing the Web site with higher resolution images. [ A link will be provided from this point when the CD is available. ]

Viewers may have found the discussion above somewhat speculative. However, there are a number of sources of evidence that support the author's contentions. The basic elements necessary for facial recognition can be found in the book In The Eye of the Beholder by Vickie Bruce and Andy Young. Additional discussion can be found along with many adverts including semi-subliminal 'faces' are on the Faces extract from Peugeot ad with rollover These indicate a variety of uses in advertising for 'faces'. But there is a more obvious supporting element in the advert itself. This emphasises another covert aspect of this ad and is also related to aggressive driving. In aggressive driving there is a necessity to confront death related anxieties or a real possibility of death itself. This topic also finds itself emphasised in a semi-subliminal aspect of this Peugeot ad.

Much more obvious than the 'faces' in the 'splash' is the skull of a cow, reminiscent of the longhorn cattle found in westerns. This 'skull' would be the first aspect of the ad that a viewer saw as they turned over the preceding magazine page. One does not need too much imagination to recognise the message that is intended to be conveyed by the 'skull'.

Semi-subliminal content such as this would seem intended to appeal, unconsciously or preconsciously, to One page version of the same Peugeot ad with caption 'stop the world dead in its tracks'those drivers who already drive in a potentially dangerous, antisocial, fashion.  However, one should bear in mind that all drivers have the potential to drive in this fashion and may also be influenced by the covert message alluded to by the imagery in the ad. 

Single page variants of this ad (see left) did not include the dead cow's skull but managed to emphasize death in the Dead in its tracks captionheadline.

In conclusion, it would seem that this - and other Peugeot ads - are produced on the basis of an assumption (or market research evidence) that an emotional response to this type of secondary imagery in ads would help ensure that Peugeot vehicles 'stood out' in the mind of potential car purchasers.   Given the knowledge that major car manufacturers and their advertising agencies have of their typical customers (their psychographic profile) it seems improbable that Peugeot produced this and other semi-subliminal images accidentally.    This view is demonstrated by consideration of other ads for Peugeot vehicles on the French Connection page.

The ASA's role

On this occasion the ASA got it right and asked for the withdrawal of this ad. On at least one other occasion regarding Peugeot ads they have asked for an ad to be withdrawn. But only partly for the right reasons. And all such ads are unlikely to be withdrawn. There is a more recent ad in the same series, unlikely to be banned, even though it promotes the same, covert, aggressive, 'speedy' message, as the 'skull' and 'faces' ad to be found on the AdsMonth page. Note that, although this second ad also contains an embedded 'face', this time it seems to be confronting the viewer who identifies with the car racing across a bridge. It thus offers a 'challenge' to the potential speeding motorist rather than an inducement to speed for the sake of speed.

Another Peugeot ad on a different theme also fell foul of the ASA and made their Top 10. Again one can note that there is more to this ad than initially meets the eye and was acknowledged by the ASA but you will probably have to await the sequel to Sexy, Subliminal and Deadly? The Psychology of Manipulative Advertising (in preparation) to find out exactly what this is. Bear in mind that this time the Peugeot ad is intended to produce a more socially acceptable asssociation between Peugeot and motivational forces. This contrasts markedly with the risk-taking, aggressive driving and death related anxiety of the previous ad. Keep this in mind and you may find the solution.

ASA banned another Peugeot ad  ASA TOP 10 complaints booklet

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Honest, Legal, Decent and Truthful?

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In Part II of this page viewers will find reproductions of the text of two background briefing papers from the Advertising Standards Authority.  The first relates to the functioning of the ASA, the second to the ASA's policy towards cigarette and tobacco advertising.  Also in Part II are a couple of extracts from the ASA code regarding alcohol advertising.

In Part III is the text of a reply from Steve Ballinger of the ASA to a request for information about any complaints the ASA had received about 'subliminal' advertising.   No such complaints have ever been received, other than one from the author. See also an associated page for correspondence with the Institute of Practitioners in Advertising (IPA), the professional 'parent' body of the ASA. This offers their views on the subject of 'subliminal' advertising. And there is also correspondence with the American Association of Advertising Agencies (AAAA).

Given the nature of ads containing embedded imagery or messages at a semi-subliminal level, the lack of complaints recorded by the ASA indicates that these potentially contentious elements are difficult to perceive.   However, in most instances in which secondary imagery is used, even if noted by lay members of the public, the relevant ads do not seem to clearly breach any of the ASA's four principles i.e. that 'All advertising should be legal, decent, honest and truthful.'  One would not therefore expect them to take any action.

However, one subsidiary factor noted in ASA briefing sheets is that ads should not bring the advertising profession into disrepute.  The author hopes that publicizing the relatively widespread use of unethical elements in such ads will indeed bring the advertising profession into disrepute and 'force' it to modify its vetting procedures.  In addition, where cigarette adverts are concerned, given that these are vetted by the ASA before publication, there is a second major issue that the ASA needs to address if it is to retain public respect.  Given the general attitude towards encouraging anti-social and unhealthy practices such as cigarette smoking, it is unlikely that members of the ASA who vet such ads would knowingly approveAsaxlog.gif (2917 bytes) their semi-subliminal content.  But, if the ASA were knowingly turning a blind eye to such unethical and manipulative ads then the ASA logo would seem to need some modification.     A revised logo such as that depicted on the right might then be more appropriate.

Read these pages in due course for an update on this matter and find out if the ASA logo returns to normal.


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Commentary and information about any of the ads or requests on this Web site can be sent by e-mail to the Webmaster

To the best of the author's knowledge none of the illustrations, in the format used on this site, are subject to copyright. If copyright has been inadvertently breached please contact the author in order to rectify the matter. All brands and logos referred to or illustrated on this site are the property of the relevant companies and copyright holders. However, commentary and other information produced by the author can be freely copied and distributed. Similarly, illustrations of ads, so long as they are accompanied by commentary or are presented in the form of parody, can also be copied and distributed but please acknowledge as the source. Translation of tobacco company ads and relevant commentary into languages other than English will be particularly welcomed.

Last Revised: 20th September, 2001


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