Consultation on Restricting Alcohol Advertising and Promotion: Analysis of responses

13 Evaluation and provision of data (Q36 and Q37)

13.1 Section 16 of the consultation paper set out the Scottish Government's commitment to robust monitoring of any future alcohol marketing restrictions. It suggested that data on alcohol marketing expenditure and local sales would be helpful in considering the impact of marketing campaigns on sales; it also noted that such data could be used to inform licencing decisions at a local level. Two questions sought views on whether the alcohol industry should be required to provide such information.

Question 36: Do you think that Scottish Government should require the alcohol industry to provide information and data on alcohol marketing campaigns in Scotland? [Yes / No /Don't know]

Question 37: Do you think that Scottish Government should require the alcohol industry to provide local alcohol sales data in Scotland? [Yes / No /Don't know]

Requiring the provision of data on marketing campaigns (Q36)

13.2 Question 36 asked respondents if they thought that the alcohol industry should be required to provide information and data on alcohol marketing campaigns in Scotland. Table 13.1 shows the following:

• Overall, around a quarter of respondents (27%) thought the alcohol industry should be required to provide information and data on alcohol marketing campaigns in Scotland, whilst two-thirds (64%) thought it should not. The remaining 9% selected 'don't know'.
• Levels of agreement with the proposition were identical for both organisations (27%) and individuals (27%). Levels of disagreement with the proposition were also identical for both organisations (64%) and individuals (64%).
• All public health and third sector organisations (100%) agreed that the alcohol industry should be required to provide information and data on alcohol marketing campaigns in Scotland. By contrast, a large majority of alcohol producers (89%) and retail and hospitality organisations (87%), and three-quarters of advertising and media organisations (75%) disagreed with this approach. Around half of events and sporting organisations (56%) said they disagreed with the approach, while a third of this group (36%) selected 'don't know'. Other organisation types were fairly evenly divided between agreement (47%) and disagreement (53%).

13.3 The arguments for and against the proposition are briefly summarised below.

13.4 It should be noted that a relatively high proportion (around a third) of events and sporting organisations selected 'don't know' at this question. These organisations (many of whom were music or cultural organisations) did not provide substantive comments to explain their view; rather, they simply said they were 'not qualified to comment' or 'not an expert in this matter'.

Percentages may not total 100% due to rounding.

Support for marketing campaign data being provided by the alcohol industry

13.5 All public health and third sector organisations, academic organisations, some local authorities and public bodies, and one in four individuals said data on alcohol marketing campaigns should be provided to the Scottish Government by the alcohol industry. Some of these respondents prefaced their comments by saying that this question would not be relevant if all alcohol marketing was banned completely. However, if a full ban were not possible, this proposal would aid transparency and accountability and might alleviate any concerns that the public has about these campaigns.

13.6 The main arguments in favour of this proposal were that:

• The alcohol industry already collects these data, and it therefore makes sense – and is not a huge administrative burden – to collate data across the whole of Scotland.
• These data could helpfully inform any evaluation of the impact of alcohol marketing campaigns. This type of evaluation could be useful not only in Scotland, but beyond. In particular, any evaluation would be useful for the planning and targeting of services (including NHS services, and educational campaigns).
• There is strong public support for data-sharing of this kind.
• This data collection could be used to (i) identify legal loopholes and any circumvention of the rules by the alcohol industry and (ii) monitor and enforce existing / planned regulations and restrictions more generally.

13.7 Respondents listed the range of data they thought should be provided. This covered items such as: aims of the campaign(s), campaign expenditure, demographic targeting, media channels being used, any anticipated or expected impacts on sales, the degree of exposure each campaign achieved within the various target populations / target subgroups, and the perceptions of children and young people, and vulnerable groups regarding any campaigns.

13.8 Some of these respondents raised caveats about how this proposal would work in practice. They asked for more detail about what data the Scottish Government wished to collect and why, noted that this could be commercially sensitive information which would need to be protected, and said that marketing campaigns were notoriously difficult to evaluate. One academic organisation made the case for using 'third party information' in this regard (by which they meant purchasing information from a commercial contractor), as had been done in other large-scale public health evaluation programmes.

Opposition to marketing campaigns data being provided by the alcohol industry

13.9 Most other organisational respondents (i.e. non-public health and third sector organisations) and a large majority of individuals said the alcohol industry should not be required to provide data on alcohol marketing campaigns in Scotland.

13.10 Respondents who opposed the alcohol industry being required to provide data on alcohol marketing campaign made the following main arguments in support of their views:

• The consultation paper does not explain why these data are needed and what use they will be put to by the Scottish Government. These data are commercially sensitive, and it would need to be clear how any Freedom of Information requests would be handled. Moreover, it is not clear whether the Scottish Government would have the resources to process and report on these data if they were provided. Without assurance on this, it would be unethical to request the data.
• The alcohol industry already faces a substantial administrative burden in complying with existing regulations. Respondents said it was not clear what the benefit of this proposal would be – if an impact assessment was undertaken, respondents believed this would show the costs of providing this information as outweighing any benefits. As with other questions, respondents emphasised the current challenging economic situation and said that any extra administrative requirements could threaten the viability of businesses – especially small businesses (distilleries, breweries).
• The proposal is unworkable in practice. It is not always possible to separate alcohol marketing from other forms of marketing (the example was given of an advert aimed at promoting a Mother's Day celebration which involved a glass of wine alongside a meal). Moreover, very few marketing campaigns are directed at Scotland only. Mostly, the alcohol industry is aiming at a UK market – and separating out data that related only to Scotland would not be feasible.

Requiring the provision of local sales data (Q37)

13.11 Question 37 asked respondents if they thought that the alcohol industry should be required to provide data on local sales in Scotland. Table 13.2 shows the following:

• Overall, around a quarter of respondents (26%) thought the alcohol industry should be required to provide data on local sales in Scotland, whilst roughly two-thirds (64%) thought it should not. The remaining 10% selected 'don't know'.
• Levels of agreement with the proposition were similar for both organisations (28%) and individuals (26%). Levels of disagreement with the proposition were also similar for both organisations (62%) and individuals (64%).
• All public health and third sector organisations (100%) agreed that the alcohol industry should be required to provide data on local sales in Scotland. By contrast, a large majority of alcohol producers (90%) and retail and hospitality organisations (87%) disagreed with this approach. Events and sporting organisations were fairly evenly divided between those who disagreed (54%) and those who selected 'don't know' (42%). Around half of advertising and media organisations disagreed with the approach (56%) with the remaining organisations in this group split between agreement (25%) and 'don't know' (19%). Among other organisation types, 59% agreed and 41% disagreed.

Percentages may not total 100% due to rounding.

13.12 The arguments for and against the proposition are briefly summarised below.

13.13 It should be noted that a relatively high proportion of events and sporting organisations (around half) and advertising and media organisations (around a quarter) selected 'don't know' at this question. These organisations did not, in general, provide substantive comments to explain their view; rather they simply said this was not their area of expertise.

Support for the alcohol industry being required to provide local alcohol sales data

13.14 All public health and third sector organisations, academic organisations, some local authorities and public bodies, and one in four individuals said the alcohol industry should be required to provide local alcohol sales data. Comments from such respondents largely echoed the points made at Question 36 (see above). In addition, this group of respondents said that:

• Self-reported alcohol consumption data (gathered through social and market research activities) are unreliable, and sales data would provide a more accurate picture of consumption patterns.
• The data which are currently available on this topic are incomplete. These data (which respondents said should be collected from both alcohol producers and retailers) would add an important (geographic) dimension to the understanding of (i) consumption patterns and (ii) the impact of local conditions (e.g. distance from shop, opening hours, type of premises, ownership arrangements, pricing and profit structures, etc.) on consumer behaviour. This kind of information would be useful for the evaluation of policy and practice.
• These data would be particularly useful for local licensing boards and would improve decision making in relation to the granting of alcohol licences.

Opposition to the alcohol industry being required to provide local alcohol sales data

13.15 Most alcohol producers, retail and hospitality organisations and a majority of individuals said the alcohol industry should not be required to provide local alcohol sales data. Such respondents also largely repeated points made in relation to Question 36 (see above).

13.16 The only additional points made related to (i) respondents' expectation that the quality of the data provided in response to this request would be poor – as wholesalers and other retailers do not necessarily know where their products are sold and (ii) comments that it was not necessary to collect these data as they were already available in aggregated form through commercial companies (Nielsen, CGA consultancy, and IWSR were specifically mentioned in this regard).