Advertising Standards Authority (United Kingdom)
Encyclopedia
Advertising
Advertising is a form of communication used to persuade an audience to take some action with respect to products, ideas, or services. Most commonly, the desired result is to drive consumer behavior with respect to a commercial offering, although political and ideological advertising is also common...
industry in the United Kingdom
United Kingdom
The United Kingdom of Great Britain and Northern IrelandIn the United Kingdom and Dependencies, other languages have been officially recognised as legitimate autochthonous languages under the European Charter for Regional or Minority Languages...
. The ASA is a non-statutory organisation and so cannot interpret or enforce legislation
Legislation
Legislation is law which has been promulgated by a legislature or other governing body, or the process of making it...
. However, its code of advertising practice
The CAP Code
The 11th edition of the CAP Code came into force in March 2003.The is administered by the Advertising Standards Authority .The ASA announced on 1st September 2010 that version 12 of the CAP Cpde was to be released...
broadly reflects legislation in many instances. The ASA is not funded by the British Government, but by a levy on the advertising industry.
Its role is to "regulate the content of advertisements, sales promotions and direct marketing in the UK" by investigating "complaints made about ads, sales promotions or direct marketing", and deciding whether such advertising complies with its advertising standards codes. These codes stipulate that "before distributing or submitting a marketing communication for publication, marketers must hold documentary evidence to prove all claims, whether direct or implied, that are capable of objective substantiation" and that "no marketing communication should mislead, or be likely to mislead, by inaccuracy, ambiguity, exaggeration, omission or otherwise".
Guy Parker has been Chief Executive of the ASA since June 2009. His salary for this role is £120,000.
History
In 1961 the Advertising AssociationAdvertising Association
The Advertising Association is a trade association that represents all sides of the advertising industry in the UK - advertisers, agencies, media, and research services...
established the Committee of Advertising Practice
Committee of Advertising Practice
The Committee of Advertising Practice is the sister organisation of the Advertising Standards Authority .CAP is primarily responsible for the constant revising and updating of the British Code of Advertising, Direct Marketing and Sales Promotion , through its Code Policy team. CAP also contains a...
(CAP) to draft the British Code of Advertising Practice (the CAP Code
The CAP Code
The 11th edition of the CAP Code came into force in March 2003.The is administered by the Advertising Standards Authority .The ASA announced on 1st September 2010 that version 12 of the CAP Cpde was to be released...
). In 1962 the industry set up the Advertising Standards Authority (so named even though it is not a public authority in the usual sense) to adjudicate on complaints that advertisements had breached the new Code. The ASA operated under an independent chairman who was to have no vested interest within the industry.
Not long after the inception of the ASA the Molony Committee considered but rejected proposals to introduce a system to regulate the advertising industry by statute. The Committee reported that it was satisfied that the industry could be regulated effectively from within by the ASA. A guarded comment within the report, however, warned that the self-regulatory system depended upon the satisfactory working of the ASA and the maintaining of acceptable standards.
Printed media
Typically, advertisements that fall in paid-for spaces in newspapers (both national and regional) and magazineMagazine
Magazines, periodicals, glossies or serials are publications, generally published on a regular schedule, containing a variety of articles. They are generally financed by advertising, by a purchase price, by pre-paid magazine subscriptions, or all three...
s published in the United Kingdom fall within the remit of the ASA. (This category covers reciprocal arrangements not involving actual payments of money.) Advertorial
Advertorial
An advertorial is an advertisement in the form of an editorial. The term "advertorial" is a portmanteau of "advertisement" and "editorial." Merriam-Webster dates the origin of the word to 1946....
s are also within the ASA's remit as long as a reciprocal arrangement of some kind is in place and control over the content of the advertorial lies with the advertiser. If the editor of the publication maintains control over the advertorial, however, the piece is likely to be seen as editorial
Editorial
An opinion piece is an article, published in a newspaper or magazine, that mainly reflects the author's opinion about the subject. Opinion pieces are featured in many periodicals.-Editorials:...
rather than advertising.
Broadcast media
In November 2004 control of the regulation of broadcast advertising, formerly undertaken by state bodies, was handed over to the ASA on a provisional two-year contract. Sponsorship credits are considered to be part of programming content and therefore fall outside the ASA's remit. Claims on shopping channelShopping channel
Shopping channels are television specialty channels that present shopping related content, particularly for home shopping enthusiasts.-USA:* America's Store* Home Shopping Network* Jewelry Television* QVC* Shop at Home Network* ShopNBC...
s can generally be considered by the ASA, but complaints about non-delivery of items are unlikely to be taken up by the ASA unless there is evidence that the shopping channel has misled people or that the non-delivery is a widespread problem.
Direct marketing
Direct mailingsDirect marketing
Direct marketing is a channel-agnostic form of advertising that allows businesses and nonprofits to communicate straight to the customer, with advertising techniques such as mobile messaging, email, interactive consumer websites, online display ads, fliers, catalog distribution, promotional...
, circulars
Flyer (pamphlet)
__notoc__A flyer or flier, also called a circular, handbill or leaflet, is a form of paper advertisement intended for wide distribution and typically posted or distributed in public place....
, leaflets
Pamphlet
A pamphlet is an unbound booklet . It may consist of a single sheet of paper that is printed on both sides and folded in half, in thirds, or in fourths , or it may consist of a few pages that are folded in half and saddle stapled at the crease to make a simple book...
, unsolicited emails
E-mail spam
Email spam, also known as junk email or unsolicited bulk email , is a subset of spam that involves nearly identical messages sent to numerous recipients by email. Definitions of spam usually include the aspects that email is unsolicited and sent in bulk. One subset of UBE is UCE...
, brochure
Brochure
A brochure is a type of leaflet. Brochures are most commonly found at places that tourists frequently visit, such as museums, major shops, and tourist information. Brochure racks or stands may suggest visits to amusement parks and other points of interest...
s and catalogues are all typically within the ASA's remit. Items such as timetables
Public transport timetable
A public transport timetable is a representation of public transport information to assist a passenger with planning a trip using public transport. A timetable details when vehicle will arrive and depart specified locations and may be organised for by route or for a particular stop...
and price lists are, however, usually outside its remit. Private correspondence, such as a doctor's letter or a bill
Bill (payment)
A bill or invoice is a document requesting payment for an order previously supplied. Presentation of a bill is common practice on the part of credit card companies, utilities, and other service providers...
, is also outside its remit, though a leaflet included with the private correspondence would be covered if it promotes a new or different product.
Internet
The ASA's remit has since March 2011 covered claims that appear on a company's own websiteWebsite
A website, also written as Web site, web site, or simply site, is a collection of related web pages containing images, videos or other digital assets. A website is hosted on at least one web server, accessible via a network such as the Internet or a private local area network through an Internet...
, as well as covering claims that appear in paid-for spaces on the Internet, including pop up ads
Pop-up ad
Pop-up ads or pop-ups are a form of online advertising on the World Wide Web intended to attract web traffic or capture email addresses. Pop-ups are generally new web browser windows to display advertisements...
, banner ads
Web banner
A web banner or banner ad is a form of advertising on the World Wide Web delivered by an ad server. This form of online advertising entails embedding an advertisement into a web page. It is intended to attract traffic to a website by linking to the website of the advertiser...
and sponsored links. The non-geographical nature of the Internet can make it hard to determine whether the ASA's remit applies. Online sales promotions (see below) are within the ASA's remit as long as they appear in "British web space".
Sales promotions
The Institute of Sales PromotionInstitute of Sales Promotion
The Institute of Sales Promotion is an organisation in the UK that represents brand owners, agencies and service partners engaged in promotional marketing. Formed in 1933, it was established as the ISP in 1979 and provides professional diplomas and certificates, best-practice guidelines and...
(ISP), working to the same Code as the ASA does, can refer complaints to the ASA when it believes that there has been a breach of the rules on sales promotions rules. There has been no clear definition of what a sales promotion is for the purpose of the Code, but examples include:
- Buy One Get One FreeBuy one, get one free"Buy one, get one free", or "Buy one, get one" is a common form of sales promotion. While rarely presented to customers in acronym form, this marketing technique is universally known in the marketing industry by the acronym BOGOF, and it is regarded as one of the most effective forms of special...
(BOGOF) offers - 25% extra free offers
- DiscountDiscounts and allowancesDiscounts and allowances are reductions to a basic price of goods or services.They can occur anywhere in the distribution channel, modifying either the manufacturer's list price , the retail price , or the list price Discounts and allowances are reductions to a basic price of goods or services.They...
ed purchase offers - Loyalty reward schemesLoyalty programLoyalty programs are structured marketing efforts that reward, and therefore encourage, loyal buying behavior — behavior which is potentially beneficial to the firm....
, such as Air MilesAir MilesAir Miles is the name of separately operated loyalty programs in Canada, the United Kingdom, Spain , the Netherlands and the Middle East, through which points are earned on purchases at participating merchants.-History:... - Scratch cardsScratchcardA scratchcard is a small card, often made of thin paper-based card for competitions and plastic to conceal PINs, where one or more areas contain concealed information which can...
, lotteriesLotteryA lottery is a form of gambling which involves the drawing of lots for a prize.Lottery is outlawed by some governments, while others endorse it to the extent of organizing a national or state lottery. It is common to find some degree of regulation of lottery by governments...
, prize drawsSweepstakesThe United States consumer sales promotion known as a sweepstake has become associated with marketing promotions targeted toward both generating enthusiasm and providing incentive reactions among customers by enticing consumers to submit free entries into drawings of chance...
.
Not all offers that give the consumer something free with a particular purchase may be considered sales promotion. For example, a mobile phone
Mobile phone
A mobile phone is a device which can make and receive telephone calls over a radio link whilst moving around a wide geographic area. It does so by connecting to a cellular network provided by a mobile network operator...
deal that offers a free Bluetooth
Bluetooth
Bluetooth is a proprietary open wireless technology standard for exchanging data over short distances from fixed and mobile devices, creating personal area networks with high levels of security...
headset may be considered as part of a package deal rather than a sales promotion.
Time limit
The ASA typically considered only advertisements that have appeared within the previous three months, although there are some exceptions to this rule, namely in cases where it was not possible for the complainant to know that the advertisement was misleading at the time it appeared, such as an advertisement for a long-term investmentInvestment
Investment has different meanings in finance and economics. Finance investment is putting money into something with the expectation of gain, that upon thorough analysis, has a high degree of security for the principal amount, as well as security of return, within an expected period of time...
.
Data protection
The ASA needs the full name and address of the complainant in order to ensure that the complaint is legitimate. These details are never disclosed without the complainant's permission, in accordance with the Data Protection Act 1998Data Protection Act 1984
The Data Protection Act 1998 is a United Kingdom Act of Parliament which defines UK law on the processing of data on identifiable living people. It is the main piece of legislation that governs the protection of personal data in the UK...
. The only cases where the ASA might ask the complainant for their permission to be named relate to complaints that a consumer has not yet received goods or wishes to be removed from a marketer's database. Even in these cases the ASA can reveal details only with the express permission of the complainant.
If the complaint comes from a competitor or someone with a trade or vested interest with the advertiser about which they are complaining, the ASA requires the company to agree to be named. This, according to the ASA, limits the number of petty or retaliatory complaints. The ASA proceeds only with the express permission of the complainant for their organisation to be named.
Investigations
The ASA begins an investigation by contacting the advertiser for its views on the advertisement and, where appropriate, substantiation of claims made in it. The ASA may on occasion seek advice from industry experts on more complex issues.Once the investigation is complete, a draft recommendation is sent to both the advertiser and the original complainant for any comments. The draft recommendation is then submitted to the independent Advertising Standards Authority Council, which adjudicates on ASA investigations. The ASA Council then discusses the complaint and the draft recommendation, and votes on whether to uphold the complaint or not. The adjudication in full is subsequently posted on the ASA's website, and made available to the press and the general public.
Appeals procedure
If there are grounds for an appeal against an adjudication , the case is reviewed by the Independent Reviewer.A request for an independent review must be made within 21 days of the adjudication, and in writing direct to the independent reviewer, stating the grounds for appeal. Only the advertiser or the original complainant may request an appeal.
There are two grounds upon which an appeal can be lodged:
- where additional evidence has come to light. If it is the advertiser that has brought additional evidence to bear, it must provide an explanation as to why the evidence was not available during the investigation.
- where there has been a substantial flaw in either the ASA Council's adjudication or the investigation process.
The Independent Reviewer's decision as to whether or not to accept an appeal is final. Similarly, the ASA Council's adjudication on a reviewed case is also final.
The independent reviewer is advised by the asa council leader.
The reason of the low amount of successful appeals is due to the fact the appeals procedure is not independent of the asa.
Copy Advice
The ASA can order advertisers not to advertise unless the CAP Copy Advice team has seen the advertisement first and allowed the advertisement to go ahead. For example, the ASA told French Connection UK LtdFrench Connection (clothing)
French Connection is a retailer and wholesaler of fashion clothing and accessories. Founded in 1972 by Stephen Marks it is based in London, is listed on the London Stock Exchange and operates globally....
, which makes the FCUK branded clothing, to have all its advertisements pre-vetted by the CAP Copy Advice team.
CAP Compliance Team
The CAP Compliance Team is the enforcement arm of the ASA and CAP. The Compliance Team works to ensure that advertisers remove their problematic claims. The Compliance Team does not report back to complainants, nor does it publish the results of its work. However, part of its work does involve contacting media owners and telling them not to take any advertisements from problematic advertisers until the CAP Copy Advice team has pre-vetted the advertisements.Office of Fair Trading
The Office of Fair TradingOffice of Fair Trading
The Office of Fair Trading is a not-for-profit and non-ministerial government department of the United Kingdom, established by the Fair Trading Act 1973, which enforces both consumer protection and competition law, acting as the UK's economic regulator...
(OFT) has powers to fine companies and bring legal actions against them. If the ASA has trouble with a repeat offender, it can refer the matter to the OFT under the Control of Misleading Advertisements Regulations 1988.
Ofcom
The ASA can also refer problematic broadcast advertisers to OfcomOfcom
Ofcom is the government-approved regulatory authority for the broadcasting and telecommunications industries in the United Kingdom. Ofcom was initially established by the Office of Communications Act 2002. It received its full authority from the Communications Act 2003...
. Broadcasters have ultimate responsibility for advertisements shown on their channels and are therefore directly answerable to Ofcom, their licensing authority. Ofcom has powers to fine and/or revoke licences. For example, following more than 1,000 complaints to the ASA about the shopping channel
Shopping channel
Shopping channels are television specialty channels that present shopping related content, particularly for home shopping enthusiasts.-USA:* America's Store* Home Shopping Network* Jewelry Television* QVC* Shop at Home Network* ShopNBC...
Auction World.tv
Auction World.tv
Auction World.tv was a British television channel which auctioned a variety of products by telephone bidding.The channel claimed to sell high-quality products at very low prices and promised reliable delivery, however doubt was cast over these claims after investigations reported by papers and...
, the ASA referred the matter to Ofcom, which found the company in breach of its licence and fined it. Auction World.tv ended up in administration
Administration (insolvency)
As a legal concept, administration is a procedure under the insolvency laws of a number of common law jurisdictions. It functions as a rescue mechanism for insolvent entities and allows them to carry on running their business. The process – an alternative to liquidation – is often known as going...
and went out of business.
Thepool.com
In an unusual step, the former chairman of the ASA, Lord Borrie Q.C., requested that advertisements for an online gambling company, thepool.com, be removed immediately pending investigation following a complaint from a member of the public. The advertisements were deemed to have breached strict ASA rules on advertising gambling to under 18s. One of the advertisements asked "Did you know it is legal to gamble at 16?" and featured the number '15' in a crossed-out sign. The ASA took a very dim view of this attempt to circumvent its Code and upheld the complaint, telling the company not to repeat the approach.Atheist Bus Campaign
On Wednesday 21 January 2009 the ASA ruled that a controversial atheist ad campaign, which sparked the ire of Christian groups for proclaiming "There is probably no God", did not break its code. Religious groups including Christian Voice complained to the Advertising Standards Authority arguing that the Atheist Bus Campaign, which ran on buses with the strapline "There is probably no God. Now stop worrying and enjoy your life", broke the advertising code on the grounds of substantiation and truthfulness.The ASA, which said that some of the complaints were that the ad was offensive and derogatory to people of faith, faced the prospect of having to decide if God existed in order to rule on Christian Voice's complaint.
However, the watchdog said that the British Humanist Association's campaign did not breach the advertising code or mislead consumers and that it therefore would not launch an investigation.
"The ASA council concluded that the ad was an expression of the advertiser's opinion and that the claims in it were not capable of objective substantiation," said the ASA. "Although the ASA acknowledges that the content of the ad would be at odds with the beliefs of many, it concluded that it was unlikely to mislead or to cause serious or widespread offence."
Israel tourism advertisement
In July 2009 the ASA banned an IsraelIsrael
The State of Israel is a parliamentary republic located in the Middle East, along the eastern shore of the Mediterranean Sea...
i tourism poster following complaints. Palestine Solidarity Campaign
Palestine Solidarity Campaign
The Palestine Solidarity Campaign is a campaign in the United Kingdom promoting solidarity with the Palestinian people. It was founded in 1982 during the build-up to Israel's invasion of Lebanon.The campaign states:...
, Jews for Justice for Palestinians
Jews for Justice for Palestinians
Jews for Justice for Palestinians is a pressure group based in the United Kingdom that advocates human and civil rights, and economic and political freedom, for the Palestinian people...
and 442 members of the public complained about how the map on the poster displayed the West Bank
West Bank
The West Bank ) of the Jordan River is the landlocked geographical eastern part of the Palestinian territories located in Western Asia. To the west, north, and south, the West Bank shares borders with the state of Israel. To the east, across the Jordan River, lies the Hashemite Kingdom of Jordan...
, Gaza Strip
Gaza Strip
thumb|Gaza city skylineThe Gaza Strip lies on the Eastern coast of the Mediterranean Sea. The Strip borders Egypt on the southwest and Israel on the south, east and north. It is about long, and between 6 and 12 kilometres wide, with a total area of...
, and the Golan Heights as part of Israel. The Israeli tourism ministry
Tourism Minister of Israel
The Tourism Minister of Israel is the political head of the Israeli Ministry of Tourism and a relatively minor position in the Israeli cabinet. The position is currently held by Stas Misezhnikov of Yisrael Beiteinu....
responded to the criticism, saying the map was a "general, schematic tourism and travel information map" and was not meant to be a political statement.
Brennan JB7 music player
3GA's advertisements for a digital jukeboxJukebox
A jukebox is a partially automated music-playing device, usually a coin-operated machine, that will play a patron's selection from self-contained media...
known as the Brennan JB7, which can import content from CD's and cassette tapes were found to be in violation of ASA guidelines because it implied that it was acceptable to rip
Ripping
Ripping is the process of copying audio or video content to a hard disk, typically from removable media. The word is used to refer to all forms of media. Despite the name, neither the media nor the data is damaged after extraction....
music, since "[it] repeatedly made reference to the benefits of the product being able to copy music but did not make clear that it was illegal to do so without the permission of the copyright owner."
3GA denied the claims, stating that the copies of music stored on the device were intended to improve accessibility, and are incidental copies without economical significance. Making private copies of audio CDs was illegal under UK law.
Other rulings
- Apple Computer UK's claim to be selling "the world's fastest personal computer" in 2004, its Power Mac G5Power Mac G5The Power Mac G5 is Apple's marketing name for models of the Power Macintosh that contains the IBM PowerPC G5 CPU. The professional-grade computer was the most powerful in Apple's lineup when it was introduced, widely hailed as the first 64-bit PC, and was touted by Apple as the fastest personal...
system, were judged to be unsubstantiated. The complaints against two other claims made in advertising for the product were not upheld. Later in August 2008, an advertisement for the company's iPhoneIPhoneThe iPhone is a line of Internet and multimedia-enabled smartphones marketed by Apple Inc. The first iPhone was unveiled by Steve Jobs, then CEO of Apple, on January 9, 2007, and released on June 29, 2007...
was banned because of false claims that it could access "all of the Internet" (when it does not support plugins such as Adobe FlashAdobe FlashAdobe Flash is a multimedia platform used to add animation, video, and interactivity to web pages. Flash is frequently used for advertisements, games and flash animations for broadcast...
or support for JavaJava (programming language)Java is a programming language originally developed by James Gosling at Sun Microsystems and released in 1995 as a core component of Sun Microsystems' Java platform. The language derives much of its syntax from C and C++ but has a simpler object model and fewer low-level facilities...
). - MicrosoftMicrosoftMicrosoft Corporation is an American public multinational corporation headquartered in Redmond, Washington, USA that develops, manufactures, licenses, and supports a wide range of products and services predominantly related to computing through its various product divisions...
's Get the facts campaign was biasBiasBias is an inclination to present or hold a partial perspective at the expense of alternatives. Bias can come in many forms.-In judgement and decision making:...
ed. - NestléNestléNestlé S.A. is the world's largest food and nutrition company. Founded and headquartered in Vevey, Switzerland, Nestlé originated in a 1905 merger of the Anglo-Swiss Milk Company, established in 1867 by brothers George Page and Charles Page, and Farine Lactée Henri Nestlé, founded in 1866 by Henri...
’s claim that it markets infant formulaInfant formulaInfant formula is a manufactured food designed and marketed for feeding to babies and infants under 12 months of age, usually prepared for bottle-feeding or cup-feeding from powder or liquid . The U.S...
“ethically and responsibly” was found to be unsupported in the face of evidence provided by the campaigning group Baby Milk Action. - L'OréalL'OréalThe L'Oréal Group is the world's largest cosmetics and beauty company. With its registered office in Paris and head office in the Paris suburb of Clichy, Hauts-de-Seine, France, it has developed activities in the field of cosmetics...
's claims in a mascaraMascaraMascara is a cosmetic commonly used to enhance the eyes. It may darken, thicken, lengthen, and/or define the eyelashes. Normally in one of three forms—liquid, cake, or cream—the modern mascara product has various formulas; however, all contain the same basic components of pigments, oils, waxes, and...
advertisement featuring actress Penélope CruzPenélope CruzPenélope Cruz Sánchez is a Spanish actress. Signed by an agent at age 15, she made her acting debut at 16 on television and her feature film debut the following year in Jamón, jamón , to critical acclaim...
"exaggerated the effect that could be achieved by using the mascara on natural lashes". In 2011, two additional makeup ads for L'OréalL'OréalThe L'Oréal Group is the world's largest cosmetics and beauty company. With its registered office in Paris and head office in the Paris suburb of Clichy, Hauts-de-Seine, France, it has developed activities in the field of cosmetics...
's were banned after after British Liberal Democrat politician, Jo SwinsonJo SwinsonJo Swinson is a Scottish Liberal Democrat politician and Member of Parliament for East Dunbartonshire constituency, a suburban and semi-rural area to the north of Glasgow in Scotland, and is the Deputy Leader of the Scottish Liberal Democrats...
, lodged complaints about ads for foundation products made by L'Oreal-owned brands, Lancôme and Maybelline, featuring actress Julia RobertsJulia RobertsJulia Fiona Roberts is an American actress. She became a Hollywood star after headlining the romantic comedy Pretty Woman , which grossed $464 million worldwide...
and supermodel Christy TurlingtonChristy TurlingtonChristy Turlington Burns is an American model best known for representing Calvin Klein from 1987 to 2007. She has worked on dozens of modeling contracts with companies including Maybelline Cosmetics and Versace. Turlington starred in her fashion documentary Catwalk and Isaac Mizrahi's Unzipped...
. The 2011 complaints stated that L'Oreal ads were not representative of the results that the products can actually achieve. ASA confirmed that both ads were misleading, without the aid of before and after shots. It ruled that the two ads breached advertising standards code for exaggeration and for being misleading, and banned them from future publication.
See also
- Advertising regulationAdvertising regulationAdvertising regulation refers to the laws and rules defining the ways in which products can be advertised in a particular region. Rules can define a wide number of different aspects, such as placement, timing, and content. In the United States, false advertising and health-related ads are regulated...
- Advertising to childrenAdvertising to childrenAdvertising to children is the act of marketing or advertising products or services to children, as defined by national legislation and advertising standards. Advertising to children is often the subject of debate, relating to the alleged influence on children’s consumption. Rules on advertising to...
- OfcomOfcomOfcom is the government-approved regulatory authority for the broadcasting and telecommunications industries in the United Kingdom. Ofcom was initially established by the Office of Communications Act 2002. It received its full authority from the Communications Act 2003...
, the British telecommunications and broadcasting regulator - Press Complaints CommissionPress Complaints CommissionThe Press Complaints Commission is a voluntary regulatory body for British printed newspapers and magazines, consisting of representatives of the major publishers. The PCC is funded by the annual levy it charges newspapers and magazines...
- ClearcastClearcastClearcast is an NGO which pre-approves most British television advertising . It came into being on January 1 2008 and took over the responsibilities of the Broadcast Advertising Clearance Centre...
, pre-approval for most British television advertising