Ad authority ‘avatars’ find five firms targeting under-18s

Advertising Standards Authority Guy Parker companies targeting under 18s
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An investigation by the UK’s Advertising Standards Authority – which used artificially intelligent ‘child avatars’ to monitor online ads – found five online gambling operators targeting under-18’s. According to chief executive Guy Parker, the technology ushers in a new era for ad regulations, which no longer has to rely on complaints from the public before taking action.


The Advertising Standards Authority has used new monitoring technology in the form of ‘child avatars’ to identify and ban five gambling ads that targeted children online. The new avatars – online profiles which simulate children’s browsing activity – identified 43 gambling operators over a two week period last year, and ultimately found five of those firms had directed ads at children, in breach of their licensing conditions.

NetEnt Product (Vikings Video Slot), Evoke Gaming (RedBet), Multilotto UK Platinum Gaming (Unibet) and Skill On Ltd (PlayOjo) were all named by the regulator, and have since “accepted their ads broke the rules.”

The initiative was unveiled by the ASA in April as heralding “the beginning of a new phase in our regulation,” and is also being used to monitor online ads directed at other vulnerable groups, and across other sectors such as alcohol and high-fat, sugar or salt foods and drinks.

In this case the avatars were deployed to identify 43 gambling operators over a two week period last year, all in “non-logged-in, online environments,” – and monitored 24 children’s websites and 20 open-access Youtube channels.

Of which, gambling ads were served on 11 of the children’s websites, but none were found on Youtube.

ASA research specialist Gemma Rosenblatt said one of the greatest benefits of the new tech was that the ASA will no longer have to wait on complaints from the public to take action.

“We think this technology has a lot of potential. It gives us a good idea of what’s out there, which is sometimes distinct compared to what people might complain about,” she explained. “You’re talking about young children who may not know what they should or shouldn’t be looking at on their own, so this gives us a sense of what’s being served to those children.”

Elaborating on the problem, ASA chief executive Guy Parker, said that relying on complaints had unfairly skewed the regulator’s attention towards certain demographics or regions more prone to complaining.

“We have a complaints inbox that comes from people who are more likely to be better off, middle aged and living in London and the South East than any other demographic,” he explained.

“Don’t tell me that people living elsewhere, or who come from different demographics, don’t have problems with advertising. They do, they’re just less likely to complain to us about them. So, it’s really important that we use intelligence other than what comes into our complaints inbox to work out what the problems are we need to fix, and think of clever ways to fix them.”

The news comes as the Gambling Commission is preparing to introduce tougher identity and age check rules for online operators, starting in May, as well as new requirements which will prevent children from playing free-to-play versions of gambling games on licensees’ websites.



The ASA explained that in in most instances, the problems arose due to errors by third-party companies who served the campaigns on behalf of the operators. Kindred’s group head of communications, Alexander Westrell, said its advert was “served by a third party without the control or knowledge of Kindred/Unibet and in breach of the contractual terms in place.”

The firm also stressed that the advert was served due a “fault in that third party’s systems” which has now been addressed but “did not lead to under-18 gambling” and that Kindred does not “knowingly derive revenue” from minors.

Nevertheless, lawyers at CMS Cameron McKenna Nabarro Olswang, David Zeffman and Tom Simpson, advise that as the ASA has shown in previous rulings on affiliate marketing, “it is the gambling operator that retains primary responsibility for compliance.”

“Gambling operators should ensure that they have oversight over the agency’s compliance with the UK Advertising Codes, for example, through regular reporting obligations or compliance reports. They should also ensure that they have sufficient contractual protection in the case of non-compliance.”

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