Ad watchdog uses avatars to catch gambling brands targeting children online


The Advertising Standards Authority (ASA) has banned adverts from five gambling operators using data collected by avatars simulating children’s online browsing behaviour.

For the first time, the ASA used monitoring technology to create online profiles that tracked the adverts being served to children as young as six over a two-week monitoring period last year.

Adverts were served to the child avatars – aged between six and 16 – a total of 10,754 times across 24 non-logged in children’s websites and 20 open-access YouTube channels. Of these, 23 individual gambling ads were served to the child avatars on 11 of the children’s websites a total of 151 times. During the same research period, no gambling ads were seen by the child avatars on the open-access YouTube channels.

While 43 gambling operators appeared in non-logged-in, online environments during the assessment period, only five of those operators were found to have broken the rules prohibiting gambling ads being targeted at under-18s.

Of the five brands found to be serving gambling ads on children’s websites, Vikings Video Slot was responsible for 10 individual ads and 122 of the ad impressions, representing 81% of the total 151 gambling ads seen.

RedBet generated 12 ad impressions from 10 unique ads, Multilotto UK Ltd generated 13 ad impressions from seven ads and PlayOjo generated three impressions from one advert. Lastly, Unibet generated one impression from one individual advert.

The initiative was part of a wider strategy by the ASA to use technology to make policing online advertising easier and more proactive. The ASA’s research specialist Gemma Rosenblatt explains that the ASA wanted to use this new technology to get under the skin of what was really happening in the online environment.

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“We think this technology has a lot of potential. It gives us a good idea of what’s out there, which is sometimes distinct compared to what people might complain about,” she tells Marketing Week. “You’re talking about young children who may not know what they should or shouldn’t be looking at on their own, so this gives us a sense of what’s being served to those children.”

The regulator instructed the gambling operators in question to take immediate action to review their online ads, the selection of media and the context in which the ads appear, to ensure they are not served to web users aged below 18.

Viking-Video-slot
The Viking Video slot ad that was targeted at children.

All the gambling companies accepted their adverts had broken the rules, although in most cases they claimed the problems arose from errors made by third-party companies who served the campaigns on their behalf.

“Brands need to make sure that their third parties stay within the rules, which we think is possible because when you look at the picture as a whole there were 43 gambling operators advertising online during the monitoring period, but only five were found to be breaking the rules,” Rosenblatt states.

While she welcomes the ASA’s use of new technology to help identify and remove gambling adverts that appeal to children Sarah Hanratty, CEO of the Senet Group – the body promoting responsible gambling standards- argues that it is crucial third parties working with gambling brands play by the same rules.

READ MORE: New rules hit gambling brands targeting under-18s

“Although all major operators have safeguards to ensure that children are not able to gamble, the industry’s obligations with regards to its advertising are clear and the licensing conditions extend equally to any third parties acting on their behalf,” she adds.

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The Gambling Commission has written to the operators concerned to ask what they are doing to guard against such adverts being served to children in the future, as new rules introduced by the commission in October confirm tough action will be taken against brands failing to meet these standards.

“Protecting children is a priority for us and we are continually looking for ways to protect the underage from gambling-related harm,” states executive director Paul Hope. “That is why next month we are introducing tougher identity and age check rules for online operators, as well as new requirements which will prevent children from playing free-to-play versions of gambling games on licensees’ websites.”

GambleAware, the charity tasked with reducing gambling harm in the UK, has responded to what it describes as the “widespread concern” about children’s exposure to gambling related marketing by commissioning research to investigate the effects on children, young people and other vulnerable people.

“Children are growing up in a very different world compared to their parents with one in eight 11 to 16 year olds reported as following gambling companies on social media,” explains GambleAware CEO, Marc Etches.

“It is deeply concerning that gambling businesses have been shown to have broken rules that prohibit gambling ads being targeted at children.”

Taking a proactive approach to ad regulation

The first stage of a wider study, the ASA chose to release the gambling results first because it saw “obvious breaches” and had serious concerns it wanted to make the operators aware of immediately, Rosenblatt explains .

The team is now in the process of analysing data showing the child avatars’ exposure to online ads for high fat, salt or sugar food and drink products, and alcohol. Collaborating with data specialist Advertising Intelligence, the team is using profiles designed to reflect the browsing characteristics of children aged between six and seven, eight and twelve, and 16.

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In order to compare these results with the types of ads being served to over 18s, the ASA has also developed avatars of an adult, a person of an indeterminate age and a profile reflecting the browsing behaviour of an adult and a child using the same device. The ambition is then to extend the avatar monitoring to logged-in environments such as Facebook, Instagram, YouTube and Twitter.

The ASA describes this proactive approach as marking a “new phase” in its regulation by using technology to better protect children and vulnerable groups online, ensuring action is taken without members of the public having to raise a complaint.

This all plays into the ASA’s five-year strategy, released in November, which features a number of goals including listening in new ways about the advertising related issues that matter most to people.

Speaking at Advertising Week Europe event last month, ASA chief executive Guy Parker explained that the regulator wanted to find new ways to fix problems with advertising without waiting for a complaint to be sent in by the public.

“We have a complaints inbox that comes from people who are more likely to be better off, middle aged and living in London and the South East than any other demographic and don’t tell me that people living elsewhere, or who come from different demographics, don’t have problems with advertising,” he stated.

“They do, they’re just less likely to complain to us about them. So, it’s really important that we use intelligence other than what comes into our complaints inbox to work out what the problems are we need to fix and think of clever ways to fix them.”





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