Advertisment
The campaign featured a number of advertisements in which individual customers spoke about the savings they achieved after switching their car insurance to the advertiser.
The advertising opened with the claim, ‘When you switch to OUTsurance, you could save big on your car insurance.’ In one version, it then featured an individual who had switched their car insurance to the advertiser and described the savings they had achieved, stating: ‘I saved €266 when I made the switch.’
The campaign featured several other individuals, who stated that they had saved €148, €182, €301, and €145 after switching.
In each advertisement, an on-screen text bubble gave the name, age and location of the customer, how much they saved and the year and manufacturer/model of the car the insurance related to.
In addition, a poster in the background stated: “OUTsurance Switch and you could save”
On screen text included the statement “Real People Unreal Savings”.
A footnote stated, ‘based on a like-for-like comparison, the customer received a gratuity for their participation’.
Complaint
Two complaints were received about the advertising in question.
Issue 1: Both complainants considered the advertisement misleading because it suggested that consumers could achieve savings of between €200 – €300 by switching to the advertiser, whereas both complainants stated that they had received quotes that were substantially higher than their existing insurance premiums and therefore did not achieve any saving. One complainant stated that they were quoted €900 compared with €446 from their existing insurer, while the other stated that they were quoted €800 compared with a previous premium of approximately €560. They considered that the advertising could mislead consumers about the savings likely to be achieved.
Issue 2: The complainants also questioned the authenticity of the savings claims featured in the advertisement. One complainant stated that the individuals featured in the advertising were paid and that their stated savings had not been verified. The complainants considered that the advertising lacked transparency and that the savings claims could mislead consumers if they were not independently substantiated.
Response
Issue 1:
The advertiser stated that the advertisements featured real customers who had switched to OUTsurance and achieved savings, and that each saving related only to that individual case rather than the wider market. They stated that all savings were calculated on a like-for-like basis by comparing the customer’s previous insurer’s renewal quote with the OUTsurance policy, with adjustments made for differences in cover and excess.
Issue 2:
The advertisers stated that the savings calculation process was subject to a detailed verification procedure designed to ensure that the figures presented reflected genuine savings achieved by customers who had switched to the advertisers. As stated in Issue 1, the advertisers stated that the savings figures were calculated using a like-for-like comparison between the customer’s new policy with the advertisers’ and the renewal invitation from the previous insurer, with a copy of the renewal invitation obtained as validation. The advertisers stated that all cover elements under both policies were reviewed and that adjustments were made necessary to account for differences in cover elements. This process was subject to an internal four-eye review to ensure accuracy. The advertisers also stated that all client testimonies in the advertisements included qualifying text that stated that the figures were based on a like-for-like policy comparison. They further disclosed the month and year in which the customer switched to the advertisers and the fact that the customers had been paid to feature in the campaign.
They provided an example through two clients from a recent campaign who had initially saved more money after switching to the advertisers, compared with the renewal offer from the customers’ previous insurer. The initial savings figures were reduced to account for differences in optional extras and/or excess amounts. The finals savings figures for the two clients were presented in the advertisements. These figures reflected the like-for-like comparison following the adjustments.
Conclusion
Complaint Not Upheld
The Independent Complaints Council considered the detail of the complaint and the advertisers’ response.
Issue 1: Not Upheld
The Council noted that the advertisements stated that consumers ‘could save’ and ‘could save big’ by switching, rather than suggesting that savings were guaranteed. The advertisements also included details of each featured customer, including their age, location, savings amount and vehicle information, making clear that the savings related to individual circumstances.
While the complainants stated that they had received higher quotes than their existing premiums, the Council considered that insurance premiums vary according to individual circumstances and that consumers would understand that quoted savings could differ from person to person. As the circumstances for each savings claim made was provided in the advertising, the Council concluded that the advertisements were not in breach of the Code on the basis suggested in the complaint.
Issue 2: Not Upheld
The Complaints Council considered the concerns raised regarding the customer testimonials and savings figures. The Council noted the from the response that the individuals featured were genuine customers and that the savings figures were based on verified, like-for-like comparisons with previous renewal quotations. They also noted that the advertisement had stated that the savings were based on a like-for-like comparison and that the customer had received a gratuity for their participation.
The Council noted the requirements of the Code and that before offering a marketing communication for publication, advertisers should satisfy themselves that they will be able to provide documentary evidence to substantiate all claims that consumers are likely to regard as objective. Relevant evidence should be sent without delay if requested by the ASAI and should be adequate to support both detailed claims and the overall impression created by the marketing communication (S. 4.10); and that advertisers who use testimonials should be able to provide relevant supporting documentation and they should hold signed and dated proof for any testimonials they use; such information should be provided to the ASAI immediately on request (S. 4.15).
The Council noted that evidence had been provided to support the savings claims featured in the advertisements. In the light of this and as the savings claims had been verified, the Council concluded that the advertisements were not in breach of the Code on the basis suggested in the complaint.
Action Required: No further action required