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How ads end up on TV... are you clear?

The way that the clearance system for TV ads works could help to inform the digital advertising debate

Mundy..."elements of the TV ad-clearance process could be applied to the digital sphere"
Mundy..."elements of the TV ad-clearance process could be applied to the digital sphere"

Clearcast is celebrating its 10th birthday this year (I know, we don’t look it!), but TV advertising preclearance dates back to the start of ITV in the 1950s. Then, the regional companies debated issues such as whether to accept the word "Cor" in an ad. Skip forward 60-odd years and the issues facing the video ad industry feel urgent and important. Digital advertising is moving at such a pace that brand- and- consumer-protection are playing catch-up.

Last year’s crisis centred on good ads appearing in bad places. A lot of work has gone on to address that, but there’s still more to do. A CNN investigation found 300 companies, including tech giants, retailers, newspapers and government agencies, ran ads on YouTube channels promoting Nazis, paedophilia and North Korean propaganda.

Clearcast’s focus on UK TV and VoD advertising is to stop bad ads appearing in good places. We work on behalf of quality, largely regulated media to ensure that claims are verified and ads don’t break industry agreed rules or cause widespread offence. We don’t advise on digital advertising beyond VoD for our clients although we’re often approached by companies that feel that digital can learn from TV. Here are some thoughts on this, based on Clearcast’s experience:

  • TV benefits from the fact that every ad can be uniquely identified by a 15-character "clock number". We clear an ad, that clearance is linked to the clock number, broadcasters receive the commercial and know where and when they can broadcast it. Without the clock number it would be much harder to keep track of the acceptability and scheduling of ads across media outlets. 

  • TV clearance is a labour-intensive business. We are mandated to seek verification on every claim, from "the most effective vacuum cleaner" to "price 14.99". This matters in TV because it is a mass medium and there is particular risk of a large number of people being offended or misled. It would be costly to reproduce the way we work across digital media where volumes are higher and the cost of advertising is far lower.
    However, it would be possible to have a system whereby an accredited competent party (advertiser/ agency/publisher) self-validates its ads against the ad code or triggers third-party validation if they have doubts. Combined with a unique ad identifier, and potentially as part of a blockchain, there would be accountability in the event the ASA were to investigate. Where digital ads don’t come from accredited parties, a simplified compliance process could operate where every ad is reviewed and triaged. Any that warrant concern could go through a simplifi ed compliance process.

  • Clearcast applies standard content indicators to VoD ads. These help media owners place them in appropriate content and make sure that, for example, kids don’t see ads with violence. Again, there is no reason why our indicators or similar ones couldn’t be applied more generally in digital advertising.

  • Over time, personalisation may exist to the point where there is almost no single "ad" as such and, of course, ads are already personalised and created on the fly. These are usually templated, and today for TV we already clear templates for ads that may have automatically generated content such as betting odds, highlighting the risks and ensuring controls are in place. 

  • The Martin Lewis case in the UK highlights that post-hoc action on harmful digital ads may not be sufficient. While a single, centralised copy-clearance body for digital may be unworkable, a centralised mechanism for validating ads and protecting consumers is beginning to look like a requirement. 

    Clearcast in numbers

    • Clearcast saw more than 61,000 TV ads in 2017, and only 44 complaints on ads were upheld by the ASA for clearance reasons (0.1% of ads seen)
    • Over 95% of the TV ads seen by Clearcast are turned around in two working days
    • More than 2,900 advertisers and agencies have submitted ads to Clearcast in the past three years
    • There are more than 9,000 current advertiser, agency and broadcaster users of Clearcast’s copy-clearance submission system

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