The Committee of Advertising Practice (CAP) and the Broadcast Committee of Advertising Practice (BCAP) call for evidence into Consulting on stricter rules for gambling ads on 22nd January 2021.
We are submitting our response and evidence to the consultation on stricter rules for gambling ads due to the research group’s1 track record and expertise in investigating: oMarketing and communication practices of the UK’s gambling operators, including transparency of responsible gambling messages and communication with the customers; o The utilisation of online gambling data to characterise, predict gambling behaviour though data-driven goal setting, social norm approaches and design patterns; oChildren’s and young adults’ experiences with gaming and gambling.
Our response and evidence are based on the following key arguments: • The marketing communication/advertisement content should not depict subjects of interest to children and young people, including sports and video gaming activities.
- The definition of ‘strong appeal’ needs to be expanded to include i.e. the use of childlike/over- exaggerated cartoons and fantasy elements.
- BCAP gambling guidance on ‘strong appeal’ has to be expanded with the following changes: use of music, include all sports and Esports in the group of themes associated with youth culture, avoid connecting to the video game market explicitly (e.g., loot boxes and Esports) and keep advertising as grounded to depicting real-life scenarios with age-appropriate people and themes (above 18).
- Advertising of the lottery must be less family related or suggested.
- Regulation around social media communication and marketing practices of gambling operators has to be considered further as our evidence suggests that social media posts, which are easily accessible by children and young people, often do not include any responsible gambling, warning messages. All social media posts published by the gambling operators are promotional. Hence, stricter rules for gambling social media advertising are required as high exposure to gambling marketing and type behaviour normalises gambling behaviour for children.
- Any evidence involving children's participation should be considered a sufficient argument for further regulatory interventions.