Consultation on Restricting Alcohol Advertising and Promotion: Analysis of responses

2 Description of the responses and respondents

2.1 This chapter provides information about the respondents to the consultation and the responses submitted.

Number of responses received and number included in the analysis

2.2 The consultation received a total of 3,034 submissions. These comprised:

• 2,272 responses submitted through Citizen Space
• 139 responses submitted by email
• 542 responses submitted as part of two campaigns organised by CAMRA (the Campaign for Real Ale) (these will be referred to as the CAMRA 1 and CAMRA 2 campaigns)
• 81 responses submitted as part of a campaign organised by the Scottish Beer and Pub Association (this will be referred to as the Publicans campaign).

2.3 Responses received by email were entered into a database and, following quality assurance checks, were added to the database of responses received through Citizen Space. In addition, 24 of the 542 CAMRA campaign responses, and 14 of the 81 Publicans campaign responses were identified as 'personalised' responses and were also added to the consultation database. The remaining 585 campaign responses were 'standard campaign responses' which were not substantively edited by the respondent. These were not entered into the consultation database. (See the discussion of campaign responses below.)

2.4 A total of 38 responses were removed from the consultation database – either because the response was entirely blank (6) or because a respondent had submitted duplicate or multiple different responses (32).^[7] In cases where the respondent submitted two duplicate responses, one response was removed and one retained. In cases where the respondent submitted multiple different responses, all the responses from the same respondent were combined into a single amalgamated response.^[8]

2.5 Thus, the analysis presented in this report is based on 2,996 responses. This comprises 2,411 substantive responses and 585 standard campaign responses.

About the respondents (substantive responses only)

2.6 Substantive responses were received from 426 organisations and 1,985 individuals (see Table 2.1).

Organisational respondents

2.7 Table 2.2 shows a breakdown of the types of organisations that responded to the consultation.

2.8 Alcohol drinks producers and related organisations were the largest group of organisations – comprising a third (33%) of all organisational respondents. This group included distillers, brewers, importers, suppliers and retailers of alcohol and non-alcoholic drinks and their representative bodies. It also included bottlers and organisations that supply glass or other services to the alcohol and drinks industry.

2.9 Public health and third sector organisations comprised the second largest group of organisational respondents (17%). This group included NHS organisations, local Alcohol and Drug Partnerships, local Health and Social Care Partnerships, Royal Colleges, children and young people's organisations, and third sector organisations including those that provide support to people with alcohol problems and / or their families. This group also included organisations with a public safety remit.

2.10 Sporting organisations and tourism and hospitality organisations comprised 12% and 11% respectively of organisational respondents. Sporting organisations included professional sporting clubs, associations, and local Highland Games groups. Tourism and hospitality organisations included hotels, restaurants, pubs and visitor attractions and their representative bodies. This latter group also included whisky tour organisers and tasting societies.

2.11 The remaining organisational responses were submitted by retail organisations (6%); music, cultural and events organisations (6%); advertising organisations (4%) and licensing and regulatory bodies (3%). This latter category included local authorities and public bodies. Print, broadcast and social media organisations, business-related organisations, and academic organisations each comprised 2% of the total organisational respondents. The remaining 2% of organisations were categorised as 'other organisation types'.

2.12 A complete list of organisational respondents is included in Annex 1.

2.13 To simplify the presentation of the findings and improve the accessibility of the report, the 12 types of organisations have been grouped in six main categories (see Table 2.3). This simplified classification is used in the tables throughout the remainder of this report. However, in some cases, the qualitative analysis will sometimes refer to sub-groups, including academic organisations, licensing and regulatory bodies, etc.

Links to the alcohol industry

2.14 The response form for the consultation invited respondents (both organisations and individuals) to provide information about any links they had to the alcohol industry. Respondents were asked to indicate if they (or their organisation) had direct, indirect, or no links.

2.15 This question was answered by 97% of respondents who submitted a substantive response. Table 2.4 shows that, of those who answered the question:

• Overall, 22% said they had direct links to the alcohol industry; 13% said they had indirect links and 65% said they had no links.
• More than half of organisations (55%) said they had direct links to the alcohol industry. In contrast only 15% of individuals said they had direct links. Almost three-quarters of individuals (73%) said they had no links.
• Among organisations, nearly all alcohol producers (94%) identified themselves as having direct links to the alcohol industry. In contrast, nearly all public health and third sector organisations (97%) said they had no links to the industry. A large majority (79%) of retail and hospitality organisations (a group which includes pubs) said they had direct links. Events and sporting organisations were more likely to say they had indirect links (62%).

Percentages may not total 100% due to rounding.

2.16 Respondents who reported having direct or indirect links to the alcohol industry were asked to say more about the type of links they had. An analysis of these responses is not presented here. However, the analysis indicated that respondents were not always consistent in the way they answered the closed question and there may have been some confusion about what constituted 'direct', 'indirect' and 'no links' to the alcohol industry. For example, some respondents involved with sports clubs that received alcohol sponsorship said they had direct links to the alcohol industry while others said they had indirect links. In addition, some individuals who said they worked in a pub reported direct links to the industry while others said they had 'no links'. The findings shown in Table 2.4 above should therefore be treated with caution.

Responses from children and young people

2.17 In addition to the engagement work carried out by Children in Scotland (see paragraph 1.10), this consultation also received submissions from several organisations that work with children and young people. In some cases, these submissions took the form of reports of (or drew on) engagement activities, discussion groups and / or focus groups carried out with children and young people on the subject of restricting alcohol advertising and promotion. An overview of the material from these responses is presented at Chapter 16 together with a summary of the findings from the Children in Scotland engagement work.

Campaign respondents

2.18 Campaign responses are a common feature of public consultation exercises. A 'campaign response' is defined as a response to a consultation that is based on a template response. The campaign organiser assists their members and supporters by providing (i) a set response to the consultation, (ii) suggested responses to each question, or (iii) a 'commentary' on the consultation and the consultation questions which people can draw on in drafting their own responses to the consultation.

2.19 'Standard' campaign responses are based on a 'standard' template, allowing the respondent to simply add their name and submit it without amendment. 'Non-standard' campaign responses are responses based on the template, but have been personalised by the respondent in some substantive way.

2.20 In this consultation, personalised campaign responses were identified by the Scottish Government and passed to the analytical team. These personalised responses were added to the analysis database and are included in the tables throughout this report. The 'standard' campaign responses (i.e. those that were not personalised) were not added to the analysis database, but were counted by the Scottish Government and the details passed to the analytical team. These counts are reported at relevant points in this report. All comments made by campaign respondents are covered in the qualitative analysis.

2.21 As noted above, this consultation received responses from two campaigns. These were organised by CAMRA (the Campaign for Real Ale) and the Scottish Beer and Pub Association. These are described below.

CAMRA campaign

2.22 CAMRA provided two versions of a standard text for respondents to submit by email: one for people living in Scotland (CAMRA 1) and one for people living outside Scotland (CAMRA 2). The CAMRA 1 campaign addressed:

• Sponsorship in sport (Qs 1–3)
• Events sponsorship (Qs 4–7)
• Outdoor advertising of alcohol (Qs 8–10)
• The display of alcohol in shops (Qs 11–13)
• Alcohol-branded merchandise (Qs 14–17)
• Advertising of low and no alcoholic drinks (Q 18)
• Print advertising (Qs 19–20)
• Online and social media advertising (Qs 21–27)
• Advertising on TV, radio and in cinemas (Qs 28–31)
• The scope of the restrictions and potential impacts on individuals and businesses (Qs 38, 40 and 41).

2.23 The CAMRA 2 campaign text was shorter and addressed:

• Events sponsorship (Q4)
• Outdoor advertising (Q8)
• The display of alcohol in shops (Q11)
• Print advertising (Q19)
• Online and social media advertising (Qs 21, 23 and 26)
• Advertising on TV and radio (Q28)
• The scope of the restrictions and potential impacts on individuals and businesses (Qs 38, 40 and 41).

2.24 Neither campaign text explicitly gave 'yes' or 'no' responses to the closed consultation questions. However, the tenor of the campaign was opposed to the introduction of restrictions on the marketing and promotion of alcohol. Therefore, for the purpose of analysis, the CAMRA campaign responses have been interpreted as answering 'no' in relation to the relevant closed questions.

2.25 Altogether, 518 standard CAMRA campaign responses were submitted. Of these, 26 reported direct links with the alcohol industry, 21 reported indirect links and 233 reported no links. Information about links to the alcohol industry was not available for 238 respondents. The full texts of the CAMRA 1 and CAMRA 2 campaign responses are provided at Annex 2.

The Scottish Beer and Pub Association Publicans' campaign

2.26 The Publicans campaign, organised by the Scottish Beer and Pub Association, addressed the following issues from the consultation:

• Sports sponsorship (Q1)
• Events sponsorship (Q4)
• Outdoor advertising (Q8)
• Alcohol-branded merchandise (Q15)
• Advertising of low and no alcoholic drinks (Q18)
• Impacts on the respondent and on the alcohol industry (Q41).

2.27 Altogether, 67 standard Publicans campaign responses were submitted. The full text of the Publicans campaign response is included at Annex 2.

2.28 It has been assumed that all the respondents in this campaign, as pub owners / managers, had direct links to the alcohol industry.

Overview of campaign responses

2.29 Table 2.5 provides a brief overview of each of the campaigns. See Annex 2 for further details.

2.30 In Chapters 3–16 of this report, the term 'campaign responses' refers to 'standard' campaign responses, and a 'campaign respondent' is an individual (or organisation) who submitted a standard campaign response.

Campaign-like responses

2.31 In addition to the campaigns described above, two other forms of campaign-like activity were identified within the responses, as follows:

• Clusters of identical or almost identical responses (fewer than 10 in most cases)
• Large numbers of responses that used common text or common phrasing, with minor amendments, suggesting collaboration in preparing responses or the sharing of responses within professional groups and business networks.

2.32 Responses of these types have been treated as substantive responses.

Response to the consultation (substantive responses only)

2.33 As noted above, there were 2,411 substantive responses to the consultation. However, not all respondents answered all the consultation questions. It was also relatively common for respondents to address multiple questions (for example, in relation to a prohibition on alcohol sponsorship) within their reply to a single question. Therefore, the response rates for individual questions (see Annex 3) are not necessarily an accurate indication of the extent to which respondents addressed individual questions. Nevertheless, the response rates provide a rough indication of the extent to which respondents engaged with the various elements of the consultation questionnaire.

2.34 Response rates for closed questions were relatively high across the consultation questionnaire, ranging from 82% at Question 7 (If alcohol sponsorship restrictions are introduced, do you think there should be a lead-in time for these?) to 96% for Question 1 (Do you think we should prohibit alcohol sports sponsorship in Scotland?).

2.35 Response rates for open questions were lower, ranging from 39% at Question 34 (Do you think that content restrictions like the Estonian model should be applied to all types of alcohol marketing?) to 80% at Question 2 (which invited further comment on aspects of a possible prohibition on sports sponsorship).

2.36 See Annex 3 for further details of response rates on a question-by-question basis.