Household

The advertising were listings on the advertisers’ website. The main page featured a banner with several safes pictured. Below that were claims regarding the advertisers’ service such as ‘Free Nationwide Doorstep Delivery’ etc. Below this it said, ‘Shop by Category’. The first heading one could select was ‘Insurance Rating Safes’. Clicking on this link brought a consumer to a page from which they could browse the available safes or filter by price and ‘Cash & Valuable Rating’.

The complainant was a competitor- Certified Safes Ireland- who believed that at least 50% of the listed safes were not certified for burglary resistance as per European Standard EN1143-1. This, they said, was a basic requirement for safe contents to be insured in Ireland and the rest of Europe. They also claimed that the rates of insurance cover possible as advertised for the majority of the safes were incorrect.

The complainant provided a link to what they claimed were the actual insurance rates for Ireland and other European Countries.

The complainant also provided insurance rating information for safes from An Garda Síochána.

The complainant said they had been made aware of this issue when one of their clients had almost purchased an uncertified safe on the basis of one the advertised ratings.

The advertisers responded with a table of sterling and euro insurance values provided to them by their supplier. This table was for the UK but with a conversion to euro provided. They also referred to their supplier’s specification sheet and the brochure which they said stated that “ratings are approximate only and may vary due to area conditions and location. Please check with your underwriter”. They did not however supply this sheet nor brochure.

The advertisers provided a link to a competitor’s listing for a safe which presented a cash and valuables value similar to the way they had presented same on their website. When asked for information that had appeared to have been omitted from their original email, the advertisers pointed to their supplier’s website as to where to find the basis for the information used on their website.

The advertisers considered that the complainant had a conflict of interest being both in the business of selling safes and also a member of The Irish Safes Ratings Group (ISRG). They said that they did not recognise the ISRG as, in their opinion, they had no expertise nor authority to rate safes and were merely an advisory group. The advertisers went on to say that their safes, where certified, comply with UK and European Standards and that these were the certificates they advertised.

The advertisers said that their website had the caveat which read “Safe ratings are approximate only and may vary due to area conditions and location. Please check with your underwriter”. Further, they said, they did not advertise that all their safes were EN1143-1 Certified as suggested by the complaint, only safes that are tested to EN1143-1 carried the ECB.S certified logo.

The advertisers said that the safe rating they followed were those based on the Blue Book (European Safe Rating Guide), and they said that it was erroneous to claim that the Gardaí had anything to do with safe ratings. The advertisers reproduced this guide for the ASA Executive and said that this mapping reflected UK insurer practice and not the EN standard itself.

The advertisers submitted that they had amended the text to the link to safes with insurance ratings. The previous text read ‘Insurance Rating Safes/ Browse our range of safes using the insurance cash/ valuable rating that insurance companies may require.’ The advertisers said that they had changed it to read ‘Insurance Rating Safes/ Option to filter our range of safes using the insurance cash/ valuable rating recommended by the UK manufacturer. We strongly advise first to consult with your insurance company’. They said that they hoped this met with the satisfaction of the Council.

Further Information:

The ASA Executive sourced information from the website of The Irish Safes Ratings Group (I.S.R.G.). The group described itself and its safe rating system as: –

Irish Safes Ratings Group (I.S.R.G.) was established to record and periodically update, recommended insurance ratings related to the overnight cash and jewellery cover for certified safes, strong rooms and secure cabinets, conforming to European standards, for the Republic of Ireland. The National Standards Authority of Ireland and The Private Security Authority sat in an observer capacity on the group.

Having been sourced directly from the Republic of Ireland’s insurance industry the I.S.R.G. rates are now the official rates recognised by The European Security Systems Association.

These ratings may be accessed here: – https://isrg.ie/safe-ratings-in-the-republic-of-ireland/

The ASA Executive noted that the website of the European Security Systems Association (ESSA) listed a summary of insurance ratings for a range of European countries, including those of Ireland and of the UK.

The ASA Executive looked at a selection of safes on the advertisers’ website listed under ‘Insurance Rating Safes’ to see if they conformed to this rating system. This selection was as follows: –

• A [REDACTED] safe was described as having a cash cover/ valuable cover €2,500.00 / €25,000.00 and an EN14450-S1 certification. Safes with a EN14450-S1 certification did not have an insurance rating on ISRG.

• A [REDACTED] safe was described as having a cash cover/ valuable cover €5,000.00 / €50,000.00 and an EN14450-S2 certification. Safes with a EN14450-S2 certification did not have an insurance rating on ISRG.

• A [REDCATED] safe was described as having a cash cover/ valuable cover €9,000.00 / €90,000.00 and an Eurograde 0/ EN 1143-1 certification. This was not in line with ISRG’s rating which recommended that the maximum cash amount that should be insured if kept in a safe with this certification and without an intruder alarm was €3,750. With an alarm this recommended cash value was €7,500. The maximum goods value was €37,500.

The ASA Executive submitted an enquiry to Insurance Ireland regarding the standing of The Irish Safes Ratings Group (I.S.R.G.). They replied: –

“To the best of [our] knowledge, the sole body responsible for determining insurance ratings for safes in the Republic of Ireland is the Irish Safes Ratings Group (ISRG).

According to officially published guidance, ISRG was established in 2016 at the request of the European Security Systems Association (ESSA) for the purpose of creating and maintaining nationally approved insurance ratings for certified safes, strong rooms, secure cabinets and deposit safes within Ireland.”

Complaint Upheld

The Independent Complaints Council considered the detail of the complaint and the advertisers’ response.

The Council noted the Code requirements that marketing communications should not mislead, or be likely to mislead, (S 4.1) or exploit consumers lack of knowledge (S 4.4) and in relation to substantiation that 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 (S 4.10).

The Council noted that the insurance ratings of another jurisdiction (UK) were submitted as evidence for the ratings stated in the advertising.

The Council also noted the information sourced by the ASA Executive about insurance ratings in Ireland, including the information on the Irish Safes Ratings Group. They further noted Insurance Ireland’s comments on the ISRG as well as the references to the ISRG in the Garda Crime Prevention National Centre of Excellence’s Crime Prevention Information Sheet on “Secure Safes and Standards”. They also noted that the ESSA website listed insurance ratings for both Ireland and the UK.

The Council considered that an Irish insurance rating was pertinent for Irish consumers. They noted that not all the safes listed under the heading “Insurance Rating Safes” had an insurance rating in Ireland with some having an insurance rating from the UK and that no indication of this rating had been provided in the advertising.

In the circumstances, the Council considered that the advertising was likely to mislead consumers and therefore was in breach of Sections 4.1, 4.4, 4.9 and 4.10 of the Code.

Action Required:

The advertisement must not reappear in its current form. The Council advised that advertisers should either use the system based in Ireland when advertising to Irish consumers or clearly state what system was being used in the advertising.