Alcohol

Advertising for West Coast Cooler on their Facebook page featured a picture of a bottle of Original West Coast Cooler positioned in the sand, on a beach, with the sea in view in the background. The post read:

“West Coast Cooler Original. This is How We Roll”

In the top left hand corner of the picture the text read:
“Girls shine on”. While the caption underneath the bottle read:
“TASTE OF Summer”

The drink aware message also featured underneath the picture “Enjoy West Coast Cooler Sensibly. Visit drinkaware.ie”

The complainants, Alcohol Action Ireland, objected to the Facebook post on the grounds that it breached the alcohol provisions of the Code. They said that it was inappropriate for the advertisers to associate an alcohol product with a beach/seaside location.

The advertisers said they hold high standards in ensuring that all of their marketing communications are directed only at the audiences for which they are intended and that the content is compliant with both the spirit and letter of the many codes by which they abide. They have strict processes and sign-off procedures in place both internally and with their marketing agencies to ensure compliance. Unfortunately, they said, on this occasion their processes failed them but the post had been removed immediately once the error came to light.

The advertisers said that their agencies normally abide by a two-pronged approval process; they are required to work with Copy Clear1 throughout the development process of their marketing communications and also get sign off from the relevant brand marketing manager for the account in question. These two approvals are necessary before any content is posted on any of their social media channels.

The advertisers said that on this occasion, however, the agency responsible for developing and publishing content on their West Coast Cooler Facebook page did not observe their approval system and that is why inappropriate content was published. They said that the agency concerned had accepted full responsibility for the error which occurred and they forwarded a letter from the agency which confirmed this.

In conclusion the advertisers said that since receiving the complaint they had taken the following steps:

• Immediately removed the post concerned from their Facebook page
• Introduced further steps to their internal processes to ensure that such a breach will not recur.
• Implemented new evolutions of their processes with their agency.
• Engaged with the Alcohol Beverage Federation of Ireland (ABFI) to conduct refresher training on all codes which govern the advertising of alcohol in Ireland.
• Introduced a requirement for all agencies with whom they work to ensure that all personnel working on their brands are trained on all codes governing alcohol advertising in Ireland.

1 An independent pre-vetting service to help ensure the advertising of alcoholic brands in Ireland complies with relevant Codes of Practice.

Complaint upheld.

The Complaints Committee considered the detail of the complaint and the advertisers’ response. They accepted that the advertisers had removed the Facebook post once it had been brought to their attention and noted the actions they had taken to ensure future compliance. Nevertheless they considered that the marketing communication had breached Section 7.7(g) of the Code.

Action Required:
As the Facebook post had been removed no further action was necessary in this case.