64 Lehman Street
'NOT IN FRONT OF THE CHILDREN' REPORT BY ALCOHOL CONCERN
I write to outline my strong concerns about the accuracy of the Alcohol Concern report on television alcohol advertising, 'Not in front of the children', published in 2007.
As you know, the Scottish Government and UK Government have each recently issued consultation papers on their respective alcohol strategies. Both consultation papers refer to the Alcohol Concern report which suggests it is being used as a basis for policy decisions.
We consider that the report was flawed from the very start in terms of its methodology. The report states that its intention was 'to gauge to what extent children were being exposed to alcohol advertising' and 'to see whether any TV alcohol adverts are placed within programmes aimed at children'. To do this, the researchers counted how many alcohol advertisements appeared during each hour of the day over two specified weeks. By showing the distribution of alcohol advertisements throughout the day, the report sought to draw conclusions about children's exposure to such advertisements. This simplistic approach (it is analogous to counting advertisements in newspapers and treating an advertisement in the local free press with the same weight as an advertisement in The Sun). Worse, it fails to take account of the audience profile for each programme. Ofcom's regulations, by which advertisers and broadcasters must abide, prevent alcohol advertisements from appearing whenever the proportion of under-18 viewers reaches 20% above the national average. This regulation applies 24 hours a day, seven days a week and means that TV alcohol adverts are never placed within programmes aimed at children.
A few days after the publication of your report in August last year, you had to withdraw and re-issue it because it completely misrepresented the above regulation, claiming that drinks advertising on TV was prohibited only if the number of children watching represented at least 20% of the entire child population in the UK (i.e. only if approximately 3m children were watching).
A few days after this correction, the report had to be re-issued again because of another entirely false claim. This time, it was the claim that alcohol advertising had been shown during The Simpsons when over 30% of the audience were under-18. This, of course, would have constituted a breach of the Ofcom regulations. It transpired no such advertisement was placed.
Even after these two corrections, however, the report still claimed that the number of alcohol advertisements rose between 3pm and 5pm. The report noted:
'This coincides with the time when most children return from school. It would be a reasonable assumption that most people in employment will not have returned home until after 5pm. Therefore the marked spike in alcohol advertising between 3pm and 5pm is at the very least puzzling.'
This seems to imply a level of intent on the part of the industry deliberately to target under-18s.
As explained above, we consider the methodology to be totally flawed and the report to be ignorant of the strict regulation that applies to the placement of alcohol advertising. We nonetheless wanted to look further into the alleged rise in alcohol advertising at this time and therefore earlier this year asked Alcohol Concern for the raw data. You have been able to provide 75% of this data (details of branded advertisements for them two specified weeks and supermarket advertisements for one specified week). From our own analysis of this data, we can see that the claim of a 'spike' is completely false.
If one takes the data for only Monday to Friday (which your report fails to do even though it emotively refers to children returning from school), the number of alcohol advertisements between 3pm and 5pm actually falls by over 50% in comparison with the two hour periods immediately before and afterwards. Even if the weekend data is included, there is still a huge fall in alcohol advertising between 3pm and 5pm rather than a 'spike'.
We are concerned that the Government consultations are taking the Alcohol Concern report at face value. In the case of the Scottish consultation, it repeats the false claim that the number of advertisements increases between 3pm and 5pm. In the case of the English consultation, the Impact Assessment that accompanies the consultation repeats the above false claim as well as the false claims concerning the regulation on placement of alcohol advertising and the appearance of alcohol advertising during The Simpsons.
The inaccuracies in this report and the insinuation that brand owners are targeting children are proving very damaging to the alcohol industry and its reputation. In responding to these consultations, we shall therefore be making the following very clear:
- the Alcohol Concern report uses flawed methodology
- the above notwithstanding, the claim that there is a spike in alcohol advertising between 3-5pm is not true: in fact, there is a trough
- (English consultation only) the claims concerning the rules on the placement of TV alcohol advertising and that alcohol advertisements appear during The Simpsons are wrong and have already been withdrawn by Alcohol concern
- The fact is that, contrary to the claims in the report, television alcohol advertising is subject to strict placement controls which are based on the audience profiling of individual programmes; these controls apply 24 hours a day seven days a week and, in conjunction with the strict rules on content, ensure that alcohol advertising does not either target or have strong appeal to under-18s.
I have a great deal of respect for the work of Alcohol concern, which is why I am disappointed that you sought to stimulate public concern on this issue in such a haphazard and disingenuous way.
In view of the importance of this issue to the alcohol industry, and the fact that it is only the Portman Group that has thus far been privy to the raw research data, I am copying this letter to relevant industry organisations to allow them if they wish, to make similar points in their own responses to the consultations.
Cc Advertising Association, ISBA, BBPA, WSTA, SWA, GVA, NACM