This week, the ASA investigated a (single) complaint against an advertorial for the People’s Postcode Lottery for its suggestion that taking part in the lottery was a solution to financial problems.
What was the ad about?
The advertorial featured a picture of a couple celebrating with their novelty Postcode Lottery cheque for £62,500 with a big red speech bubble stating “We had to postpone the wedding when Craig lost his job.” The ad further went on, “Couple’s wedding is back on after they scooped £62,500 on People’s Postcode Lottery”. It told the story of Angie and Craig, an NHS nurse and her fiancé who had been made redundant days after they had put the deposit down for their wedding day.
The ad explained that the unlucky couple had to put their marital plans on hold when they heard Craig had been made redundant. In a change of fortune, thanks to the People’s Postcode Lottery, they were not only able to continue with their wedding plans but were even going to be able to pay for their honeymoon.
Postcode Lottery Limited (which trades as People’s Postcode Lottery) did not think that the ad breached the CAP Code, saying the advertorial didn’t suggest that the couple had been struggling financially before they won the money. They argued that the ad didn’t specifically refer to salary or debts and there was no suggestion that the couple weren’t able to pay for things like food or bills. There were various implications from the ad itself that this was not the case: Angie and Craig were pictured in front of a comfortable home, it referenced the fact that Craig had landed a new job and Angie had had a job throughout Craig’s redundancy.
People’s Postcode Lottery also raised the fact that a wedding is a particular and significant cost which many couples have to save up for, rather than being a sign of ongoing financial burdens and struggling to make ends meet. They argued that the ad showed a benefit of winning the Postcode Lottery, which is permissible under the CAP Code, rather than making out it was essential to enter to solve money problems.
The ASA rejected the arguments raised by the People’s Postcode Lottery and upheld the complaint, considering the advert to breach the CAP Code by suggesting that participating in a lottery can be a solution to financial concerns, an alternative to employment or a way to achieve financial security. The ASA considered that people would make a direct connection between the fact that Angie and Craig had won £62,500 through the lottery and being able to kick off their wedding planning again.
A particular line in the ad was of significance to the ASA: “We had to put the wedding on hold because we didn’t know how long he’d be out of work. Awful thoughts go through your mind.” They considered that this showed just how worried the couple (and, in particular, Angie) was about Craig’s redundancy and how that would affect their wedding plans. They also put some weight on the fact that the couple had paid a deposit for their wedding before Craig was made redundant and that this would have put significant pressure on the couple, and that the couple appeared to have continued to buy tickets to the Postcode Lottery even during that time. To the ASA, this suggested that winning the People’s Postcode Lottery had been used as a way to solve Angie and Craig’s financial worries.
The ad has been banned and the People’s Postcode Lottery mustn’t imply that participating in a lottery is a solution to financial concerns. They found this ad to be in breach of CAP Code rule 17.3.
In our view, the advertiser was really unlucky here, and it seems the ASA might have been overzealous on this one. On a different day, this might have been decided differently
But, ads for gambling products must ensure they describe prizes and their impact very carefully, particularly when describing the practical benefits they may have for some people with financial concerns.
Even with the parts of Craig and Angie’s story which might suggest otherwise, the ASA found that “financial concerns” didn’t necessarily have to be ongoing, day-to-day struggles, and could include a significant, non-essential one-off expense like a wedding.
“We considered that, along with the presentation of the couple as being stressed because they could no longer afford their wedding, had the effect of suggesting that winning the People’s Postcode Lottery was able to provide a solution to their financial concerns regarding the payment of their wedding.”