Unnoticed Transparency — The Useful Text You’ve Probably Not Read
I reposted an article on LinkedIn reporting the ASA’s ban on Deliveroo’s Autumn 2019 TV campaign. The fantasy nature of the creative treatment was inadvertently interpreted rather literally by viewers. Consequently, the ASA received complaints from many who felt the commercial was misleading. Deliveroo offered to clarify the ambiguity with an on-screen caveat, but this was deemed unlikely to resolve the issue, and the ad was pulled.
The hashtag of the article I began trending and my own post attracted the ire of several people. I’m always intrigued by negative comments, so I dug deeper into what was winding them up so much. Some of the negativity surrounded my use of the word ‘supers’ — the industry shorthand for superimposed text, aka. the ‘small print’ that runs along the bottom of TV ads — which they felt only reinforced their belief that advertising people are deliberately evasive and misleading. I explained my terminology. For many other commenters it was simply the nature of ‘small print’ itself that really ground their gears. They found the text difficult to read, or not held on the screen for long enough — with pointed accusations that advertisers were somehow deliberately trying to mislead viewers by making the text difficult to read. One person stated they had never actually noticed TV ads had text at the bottom of the screen.
So, I draw your attention to the text at the bottom of ads — because it’s there for the benefit of viewers:
Why is there ‘small print’ on ads?
TV commercials are typically 10, 20, 30 or 40 seconds. That’s not much time to promote a product or service while also providing detailed in-depth background information. A commercial gets the ball rolling — it gets viewers thinking about the advertiser, motivates them go pick up a product in store, look at a website, or contact the advertiser for more information. People don’t make major life decisions based on single viewing of a TV commercial. Nonetheless, TV ads need to be upfront about anything of importance that a viewer would likely want to know before proceeding further with their initial interest — e.g. Eligibility criteria, APR, or the date a sale period ends.
Does every ad have small print, and I’ve simply not noticed it?
Most ads (regardless of the advertiser) will have some amount of clarification text at the bottom of the screen. But if the advertiser isn’t making any bold claims or featuring pricing information — e.g. they’re simply raising awareness of their brand — there might be no need for additional text.
Who decides on the wording of the small print?
TV commercials adhere to the BCAP Code, the legal guidelines for the TV advertising industry. The code ensures commercials are honest and appropriate for viewers. The code is published by the ASA (Advertising Standards Authority). Responsibility for checking that every TV commercial adheres to these guidelines lies with a body jointly funded by the UK’s major broadcasters, Clearcast.
TV ads cannot be aired without Clearcast’s approval — and their involvement in the process begins before a commercial even goes into production. If they believe anything needs to clarified, or called to viewers’ attention — they’ll request substantiation from the advertiser to check they are legally able to stand by the claims they are making. Clearcast will suggest to us (the production company) the appropriate text to place at the bottom of the commercial.
To be clear, small print CANNOT CONTRADICT anything in the commercial message, e.g. a bold claim or stunning price point cannot be undone by a loophole in the small print. The ‘supers’ serve only to provide additional information to supplement the message in the commercial. To quote the exact wording from the BCAP code:
“Superimposed text may be used to expand or clarify an offer or to make minor qualifications. It may also be used to resolve minor ambiguities. Superimposed text that flatly contradicts a claim made elsewhere in the advertisement is not acceptable.”
Why is the text so small?
Actually, although the text may not dominate the screen — it is larger than the ‘small print’ in most other media. The size of on-screen text is carefully prescribed using precise pixel measurements — using the vertical height of the shortest letter as the measurement benchmark.
Furthermore, in Spring 2019 the guidelines were updated to increase the boldness and size of the text to maintain legibility on large HD displays. The excessive horizontal squeezing or kerning adjustment (closing the gaps between letters) common in the days of 4:3 ratio and standard-definition TV is no longer an acceptable practise. The text must be bright white, black, or a neutral grey — depending on the content of the commercial. All of this ensures that no advertiser can shirk their responsibility to make the text as legible as possible.
But, I don’t get time to read it all!
The duration of supers in an ad is calculated by an industry-wide calculation, which includes a realistic period of ‘recognition time’ to give viewers opportunity to spot the text is there prior to choosing to read it. The calculation ensures most viewers can read all the text in a commercial… if they choose to. Of course, viewers will see a commercial several times before choosing to act on it — and those repeat exposures give viewers additional opportunities to read the text.
The ASA conducted research with TV viewers into the real-world understanding of supers:
“The research suggests that only a small proportion of respondents spontaneously recalled having seen supers. This and similar findings must be balanced with other findings, however. Viewers tend to watch ads passively only becoming more active when something prompts attention (e.g. an ad for something they are interested in). The research also suggests that viewers generally understand what supers are for and that the information contained in them is likely to be important. Moreover, the prompted phases of the research show strongly that viewers can read supers (provided they are legible), if they want to.”
Who enforces all this? Can I complain?
Advertisers, agencies, and broadcasters all go to great lengths to ensure that television remains the most trusted of all advertising channels — after all, it’s not in anyone’s interests to damage the reputation of the very medium central to our own businesses.
The Advertising Standards Authority will remove any commercial from air if it upholds a complaint against it, even if that complaint came from just a single viewer. An advertiser whose ad gets pulled doesn’t get their money back, their advertising investment is gone. So, with substantial budgets at stake, it’s in the advertiser’s interest to be entirely transparent and honest — and to remove ambiguity by placing easily readable clarifications at the bottom of their commercial.
