Restricting alcohol advertising and promotion: consultation

11. Online marketing

“Ads pop up all the time on social media and despite blocking them more just appear – it triggers me massively.”

Person in recovery

11.1 Seeing, and actively participating with, online alcohol marketing is associated with increased alcohol consumption and an increased risk of binge and hazardous drinking behaviours.

11.2 We know that online advertising spending is growing as a proportion of total advertising spending, £16bn was spent on online advertising in 2020 in the UK.

11.3 Over 2000 online alcohol marketing campaigns were operated on Facebook, Instagram, Snapchat, Twitter and Youtube during a two month period in 2020.

11.4 Most children today are active online from an early age. In many instances children and young people are the early adopters of popular websites and applications, driving the trends we later see among adults. Nearly all (97%) 5-15 year olds in UK went online in 2020. UK children aged 7 to 16 years old who went online estimated that they spent 3 hours 48 minutes a day online on average, compared to 2 hours 11 minutes in 2019.

11.5 This includes children and young people interacting with many different types of media such as websites, games, on-demand players (such as BBC iPlayer), social media and video sharing platforms (such as YouTube or TikTok).

11.6 Social media is an integral part of most children and young people’s lives. In the UK, despite many sites setting a minimum user age of 13, just over one fifth of 8-11 year olds (21%) have a social media profile rising to 43% of 11 year olds. By the age of 13 (the minimum age requirement) more than half have a profile and almost all 15 year olds.

11.7 We know that in spending a vast amount of time online, children and young people see and interact with alcohol marketing. Research shows that just over a quarter (27.3%) of 11-19 year olds in the UK had seen an alcohol advert on YouTube, Tumblr, Facebook, Snapchat, Instagram or other social media, in the week prior to being surveyed. Another survey of 11-19 year olds found that more than one-in-ten respondents had actively participated in one form of alcohol marketing on social-media, one-in-twenty had liked an alcohol brand or shared an alcohol brand status, tweet or picture.

What does online alcohol marketing include?

11.8 The online space provides an additional environment for the repetition and extension of offline marketing techniques such as television style adverts on video sharing platforms or billboard type adverts as banner/pop up adverts. It also provides the opportunity for interactive possibilities like targeted vlogs, filters on social media and viral marketing.

11.9 Online alcohol marketing includes adverts displayed on alcohol brands’ own websites and social media channels (owned media). As well as paid adverts on websites, social media platforms or search engines, or by influencers (paid media).

11.10 On top of these commercial techniques, consumers post and share alcohol content on their own social media profiles (consumer-generated content).

11.11 Whilst traditional media channels like television display the same advertisement to all people watching, online platforms have sophisticated data gathering methods which enable them to develop consumer profiles and to target that specific consumer with personalised advertising in real time based on their behaviour and interests. This is called programmatic advertising.

Owned Media

Brand websites and social media channels post content (photos and videos).

User-generated Content

Consumers posting pictures on social media and sharing content.

Paid Media

Paid advertising on banners and pop-ups on websites and social media.

Programmatic advertising (consumers targeted based on data associated with them and the interests they have).

Influencers paid to post about products.

Owned media

11.12 Alcohol branded social media channels post content, including photos and videos, to individuals who follow or ‘like’ them. High – quality posts advertise the product/s sold and show the alcoholic drink being consumed in desirable locations or contexts as well as highlighting sponsorships or tie-ins with celebrities.

11.13 Children and young people would see alcohol content if they followed or liked the alcohol brand or if they followed sponsored celebrities, influencers or sports people who advertise the brand.

11.14 This is despite age gating, which is the process of checking age of users before allowing access. UK research has found that while age verification can prevent individuals whose profile states they are under 18 years of age accessing alcohol marketing on Facebook, users of all ages can access alcohol marketing on Twitter and YouTube.

11.15 Research from the United States found YouTube profiles created for fictional users aged 14, 17 and 19 were able to subscribe to 100% of the alcohol brand YouTube pages explored.

Question 21

Do you think we should restrict alcohol branded social media channels and websites in Scotland?

Please tick one

Yes

No

Don’t Know

Please explain your answer in the text box.

Question 22

What, if any, exceptions do you think there should be to prohibiting alcohol branded social media channels and websites in Scotland?

Please provide your answer in the text box.

Paid media

11.16 Alcohol companies also pay for advertising outside of their own websites and social media channels, as shown by a recent study by the ASA. A high volume of paid alcohol advertising online is data-driven. It targets consumers based on data associated with them. For example, through other interests that consumers have (e.g. music or gardening) determined by previous browsing history and searches (known as user targeted advertising and retargeted advertising). Other online advertising continues to be contextually targeted, meaning that it is targeted to be relevant to the content of the website upon which it appears.

11.17 The current regulatory system is clear that online alcohol advertising should not be targeted towards under 18’s. Also that advertisers should use both known age data and data about interests to ensure that this does not happen. The ASA researched alcohol advertising in social media specifically and found that:

• A handful of campaigns did not appear to use any age targeting at all
• For the majority that selected an age 18+ audience, many didn’t select any ‘interests’ options to give greater confidence in reaching an adult, rather than a child
• There was limited evidence of advertisers actively barring their ads from being targeted to audience groups that have interests in topics and themes very strongly associated with under 18s.

11.18 This links in with broader issues around advertising online and age-restricted content, as set out by the UK Government, including:

• the shared use of devices, online profiles and accounts between adults and children mean that there will perhaps not be clear age-based data or interests-based data showing that a user is under 18. Research from the ASA found that an avatar mimicking the profile of a child and adult sharing a device was served a similar proportion of unhealthy food adverts as avatars mimicking the profile of an adult
• the false reporting of users’ ages. Ofcom data indicates that levels of misreporting of age on social media have remained steady over the past 10 years – around 20% of 8 to 11 year olds report using social media accounts, despite the minimum age for such accounts being 13.
• inaccuracy in using interest-based factors and other behavioural data as a proxy for age.

11.19 However, there are wider effects to users who would prefer not to receive targeted messages, especially those in recovery.

11.20 Adverts are tweaked and personalised to optimise the effectiveness of them to that particular individual. This may result in alcohol marketing online being uniquely harmful to vulnerable consumers as more adverts might be served to high-volume consumers.

11.21 This can include targeting at specific times and in specific places where people can be most vulnerable to alcohol marketing messages. This may appear in user’s digital feeds while they are drinking alcohol including when they are intoxicated.

11.22 Advertising online can also allow for instantaneous purchase through ‘buy buttons’ creating a seamless flow from identifying consumer preferences, exposing consumers to a targeted piece of marketing to converting this into purchase.

11.23 This is of particular concern for higher-risk drinkers or those who may be in recovery from alcohol problems.

Question 23

Do you think we should restrict paid alcohol advertising online in Scotland?

Examples include adverts appearing on websites, via pop ups, on social media platforms, on search engines, or influencer advertising.

Please tick one

Yes

No

Don’t Know

Please explain your answer in the text box.

Question 24

What types of paid alcohol advertising do you think should be covered by any restrictions?

Please provide your answer in the text box.

Question 25

What, if any, exceptions do you think should there be to restricting paid alcohol advertising online?

Please provide your answer in the text box.

User-generated content

11.24 User-generated marketing includes sharing or liking an alcohol brand’s content including written posts, photos, videos, games and competitions. This extends the reach of the original marketing and enhances the credibility of it.

11.25 Consumers also create and post text, pictures or videos featuring alcohol on their social media profiles, independently of alcohol companies. For example. the NekNominate drinking game involved an individual posting a video of themselves drinking before tagging a peer on social media to do the same within 24 hours.

11.26 A UK survey of 400 18-25 year olds found that they were aware of, and took part in alcohol marketing on social media, and that this is linked with alcohol consumption and higher-risk drinking. The most common methods were sharing photos of friends and peers drinking, sharing videos of drinking, sending multimedia instant messages about drinking, sharing memes and cartoons. On average participants engaged with four of the methods surveyed.

11.27 We know that social media can be a public platform for young people to endorse alcohol brands and use these as an extension of their identity. Young people in focus groups describe the alcohol brands they are associated with on social media as influencing their choices of new friends, and carefully selecting them on this basis – ‘I wouldn’t be friends with someone if they were liking too much rubbish.’. This lends credibility and authenticity to alcohol brands.

11.28 In Finland, commercial marketing of mild alcoholic beverages (less than 22% ABV) is banned on social media when it is either produced by consumers or produced by an alcohol company and intended to be shared by consumers. This means alcohol companies cannot use content originally uploaded by consumers (user generated) nor can they create content which is specifically aimed for consumers to share (which once shared becomes user generated).

Question 26

Do you think we should restrict alcohol companies from sharing promotional content on social media (e.g. filters, videos or posts) – whether this is produced by them or by consumers?

Please tick one

Yes

No

Don’t Know

Please explain your answer in the text box.

Question 27

What, if any, exceptions do you think there should be from restricting alcohol companies from sharing promotional content on social media (e.g. filters, videos or posts) – whether this is produced by them or by consumers?

Please provide your answer in the text box.