Ofcom has resolved a complaint against Channel 4 over confusion caused by the airing of interactive TV advertising involving an exclusive Prometheus trailer and viewer tweets. The communications regulator expressed concerns that Channel 4’s use of audience tweets in TV advertising created ambiguity between what the audience might consider to be advertising and editorial content.
In April 2012 Channel 4 transmitted two pieces of content in advertising breaks during an episode of Homeland promoting the film Prometheus.
The first piece of content consisted of a full-screen Channel 4 logo, with the channel’s regular continuity announcer announcing an upcoming trailer for Ridley Scott’s Prometheus, together with a request for viewers to tweet #areyouseeingthis saying what they thought of the film. This was followed by the film trailer for Prometheus.
In the next break, the second piece of content included viewer tweets referring to the trailer and film, including:
“Prometheus is shaping up to be the best film of the year”
“Awesome cast, fantastic director. Can’t wait”
“Prometheus looks beautiful, intelligent, flawless, inspiring and proper scary”
Ofcom received a complaint from a viewer who was confused as to whether the material was an impartial continuity announcement or a paid advertisement.
Advertising and Editorial Separation
Rule 11 of Ofcom’s Code of Scheduling Television Advertising requires broadcasters to ensure that television advertising is readily recognisable and distinguishable from editorial content and kept distinct from other parts of the programme service. In addition, rule 2.1 of the BCAP Code also requires advertising to be distinct from editorial.
Channel 4 confirmed that the material was advertising broadcast in commercial airtime. Both ads had been cleared in advance by Clearcast. Channel 4 had also taken steps to ensure compliance with the various advertising rules, including ensuring that a blank screen was inserted at the end of the programme before the advertisement in order to highlight the end of the programme and beginning of the advertising break.
Ofcom accepted that viewers were unlikely to doubt that Homeland had been interrupted for a break. However, the presentation style of the Prometheus content risked confusing viewers in respect of its status.
Ofcom highlighted specific elements within the Prometheus content which viewers would traditionally associate with editorial content, such as:
- the Channel 4 logo displayed prominently during the beginning of the advert
- the voice of the Channel 4 continuity announcer
- language which suggested Channel 4’s ownership and endorsement of the material
- the request for viewers to tweet, to the channel, their views on the content
Ofcom believed such viewer interaction was more commonly associated with television programmes than with advertising. Ofcom also noted that the tweets shown in the second advert were wholly positive about the film and it was unclear to viewers whether the tweets had been selected by Channel 4 for editorial reasons or for advertising purposes.
Ofcom expressed concern about the degree to which the material was recognisable as advertising, but considered the case had been resolved. Channel 4 had taken subsequent steps to ensure that similar advertising material in future was clearer as to its nature. In particular, the broadcaster said it would include a caption clearly stating that such material was advertising.
Ofcom’s decision will be of interest to broadcasters and advertisers who are increasingly looking to interactive advertising as a method of encouraging consumers to engage with products, brands and services. Ofcom’s concerns as to the presentation of such adverts may reduce as broadcasters use viewer interaction in advertisements more often and viewers start to recognise this type of material more obviously as advertising.