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BULLETIN No: 8 Telephone: 020 7306 7743 Facsimile: 020 7306 7737 Issued: Monday 17 February 2003 Television Advertising Complaints REPORT How Television Advertising is Controlled The ITC is the statutory body created by the Broadcasting Act 1990 to license and regulate commercial television in the UK. Its remit extends to all commercially funded television services broadcasting from the UK, including satellite and cable services. The Act requires the ITC to draw up and enforce a code on advertising standards. The ITC also has a duty under the Control of Misleading Advertisements Regulations 1988 to consider complaints about misleading television advertisements. The ITC sets standards for television advertising through its Advertising Standards Code. This is adopted and reviewed after wide public consultation. The ITC also consults regularly with the Government and has a duty to carry out any government directions about categories of products and services which may or may not be advertised. In addition, the ITC receives regular advice on advertising standards from an external advisory committee comprising representatives of both consumer and advertising interests. The ITC enforces compliance through a combination of prevetting requirements and direct intervention. It requires the television companies it licenses to employ trained staff to check advertising carefully before accepting it for transmission. In particular they are required to satisfy themselves that any claims are accurate and, where appropriate, to inspect documentary evidence or seek the advice of independent consultants. The majority of television advertising is vetted by a central body called the Broadcast Advertising Clearance Centre (BACC) who act on behalf of a number of ITC licensees collectively, including ITV, GMTV, Channel 4, Channel 5, BSkyB and UKTV. In practice, most television advertising is submitted initially in script form and clearance for film production is given only when the BACC, or the individual company, is satisfied that there will be no breach of the rules. Where there is doubt about interpretation of the rules the television companies are encouraged to seek guidance from the ITC. These procedures, which are more searching than those applicable to any other advertising medium, ensure that the vast majority of advertisements which appear on television do not breach the rules. The ITC does, however, monitor the finished output closely and where necessary intervenes to require non-complying advertising to be withdrawn. A decision by ITC to suspend or discontinue an advertisement has mandatory and immediate effect and there are severe sanctions for non-compliance. The ITC considers all complaints which it receives about advertising and, where an investigation is necessary, requires the television companies to submit background material to it promptly so that an assessment may be made with a minimum of delay. All complainants receive a personal reply to their complaint. CONTENTS 1 Complaints of Substance 9 14 Summary of Other Complaints Analysis Complaints of Substance The following complaints appear to raise issues of substance in relation to the interpretation of the ITC Code of Advertising Standards. OFFENSIVE Take a Break Magazine - Meals on Wheels Mustoe Merriman Levy COMPLAINTS FROM BACKGROUND 318 viewers Take a Break is a 'coffee break' magazine. The advertisement showed a driver of a meals-on-wheels van reading the magazine parked outside a block of flats. The voice-over said "whatever you're doing it can wait - while you Take a Break". As the driver continued to read, an elderly lady was shown in her flat at her kitchen table, an empty plate in front of her, waiting for her meal to be delivered. The scene in the flat was depicted as bleak, the elderly woman as despondent. Complainants, including a number of care workers and three charities concerned with the welfare of the elderly, objected that the advertisement degraded the elderly, that it could induce anxiety among the elderly about the reliability of the social services they receive, and that it denigrated meals-onwheels and similar welfare services. More generally, many considered the idea of using this scenario as the subject of a joke to be profoundly offensive. Soon after the volume of complaint became clear the commercial was voluntarily withdrawn by the advertising agency. The BACC explained that it would not have cleared the advertising had it been able to anticipate the depth of viewer reaction. It's judgement when assessing the pre-production scripts and on seeing the advertisement before transmission was that the delivery woman would be understood just to be taking a short break. Since the van was shown parked outside the building it was delivering to the BACC believed it would have been clear that the delivery was merely a little late and that the driver was distracted, not indifferent. The commercial finished with a shot of the magazine on the seat of the van which, BACC argued, would show that the driver had remembered her duties and delivered the meal. However, with hindsight it accepted that the disappointment of an elderly person was not a suitable subject for humour and that this lesson would be borne in mind in future. ISSUE ASSESSMENT 1 The ITC judged that the advertisement had made light of the fear and loneliness of some of society's most vulnerable members and that it had shown one elderly lady, with whom others could easily identify, in a degrading light. That the commercial was felt by many viewers to be offensive was clear, and the ITC acknowledged the prompt action taken by the agency to remove it once this strength of feeling became known. The ITC agreed with viewers that the advertising had been unsuitable for broadcast and required it not to be re-transmitted in its current form. CONCLUSION Complaints upheld. Breach of ITC Code Rule 6.1 OFFENSIVE Marmite - Lifeguard kiss BMP DDB Needham COMPLAINTS FROM BACKGROUND 71 viewers The advertisement opens with a shot of a beach lifeguard preparing and eating a Marmite sandwich. He sees a male swimmer in distress and goes to the rescue. The swimmer, unconscious when brought back to the beach, receives the 'kiss of life' from the lifeguard. Almost immediately, the swimmer regains consciousness and clamps his mouth to the lifeguard's. The lifeguard fends him off. The commercial ends with a pack shot of a jar of Marmite and the strap-line "You either love it or hate it". Viewers complained that the advertising portrayed a homosexual act and was unsuitable for broadcast at times when children might be watching. Some also objected that the scenario undermined the role of lifeguards, trivialised the act of resuscitation and could potentially dissuade people from learning the technique. One complainant said the idea of food being transferred between mouths was offensive. The ITC judged that Marmite's "love it or hate it" campaign was now well established and viewers would generally have understood the joke: that the rescued man so liked the taste of Marmite that on coming round he acted impulsively and grabbed hold of the lifeguard. The ITC did not agree that the scenario portrayed homosexual intimacy, or indeed sexual or romantic activity of any sort. Neither did it agree that the commercial posed any threat either to the standing of lifeguards or to the willingness of people to learn resuscitation techniques. Judging the clearly jokey scenario of a man enjoying the taste of food on another's mouth unlikely to generate widespread offence the ITC ruled that intervention would be inappropriate. CONCLUSION Complaints not upheld. ISSUE ASSESSMENT 2 OFFENSIVE Time Life - The Bible Arm-Direct COMPLAINTS FROM BACKGROUND 3 viewers An advertisement for The Bible, a Time Life video telling the story of Jesus, was shown during Milkshake, the children's segment on Channel Five. It included a shot of Jesus, bleeding from the forehead from wearing a crown of thorns. Viewers complained that their children had been upset by the advertisement. They did not think it should have been shown during children's television. Five explained that the advertisement did not carry an ex-kids restriction, designed to keep unsuitable material away from programmes made for or likely to appeal to children. It did not therefore consider the material inappropriate for broadcast during Milkshake. The ITC judged that the graphic image of a bleeding forehead could be capable of distressing children and as such it was unsuitable for broadcast during children's programmes. It instructed BACC to impose an ex-kids restriction with immediate effect pending the outcome of the full investigation. The advertiser accepted that some of the images might be upsetting to very young children and agreed to the restriction. In view of the fact that children are likely to find images of bleeding wounds distressing, the ITC was concerned that the BACC had originally approved the advertisement without any restriction. It warned that any future advertising with similar imagery should take this into consideration. It confirmed that the current version of the advertisement should retain the exkids restriction already imposed. CONCLUSION Complaints upheld. Breach of ITC Code Rule 7.3.7. ISSUE ASSESSMENT OFFENSIVE Pleasure Zone COMPLAINTS FROM BACKGROUND 4 viewers A range of sex aids and fetish clothing was advertised between 8pm and 6am on Pleasure Zone, a new interactive teleshopping channel aimed at the adult market. Viewers were concerned that these products were being advertised well before the watershed on an unencrypted service that could be easily accessed by children. Pleasure Zone apologised to viewers who had been offended by its output and agreed to change its schedule. Retail products of a clearly adult nature, such as fetish items and toys, would only be available in its "Shop by Night" section between 10pm and 6am. Other items, mainly lingerie and condoms, would be accessible at all times in the "Shop by Day" section. It also reordered the menu so that viewers would have to go through at least five pages of content to access the more explicit products. ISSUE ASSESSMENT 3 Prior to the launch of Pleasure Zone, the ITC had discussed the content of the service and scheduling restrictions with the channel. It advised that any adult material would have to be scheduled appropriately according to viewer expectation of what could and could not be shown at different times. The ITC was concerned that Pleasure Zone appeared to have disregarded this advice and agreed with the viewers that the adult content of the service was unsuitable for broadcast from 8pm. It noted Pleasure Zone had taken prompt action to change its schedule but judged that 10pm was still too early a time to start advertising the products listed under the "Erotic" heading which included dildos, jelly vibrators and vibrators. It required the channel to make the necessary changes to its schedule to reflect that this type of content is not broadcast before 10.30 and to bring it into line with other channels carrying content of a similar nature. CONCLUSION Complaints upheld. Breach of ITC Code Rule 7.3.7. HARMFUL Bacardi Breezer – 9 Lives McCann-Erickson COMPLAINTS FROM BACKGROUND 1 viewer An advertisement for Bacardi Breezer showed a woman in a sports car swerve to avoid a cat that had run into the road. The cat then jumped into the car and they drove off together. A viewer complained it was irresponsible that an advertisement for alcohol should feature a car because it implied that drinking and driving was acceptable. The ITC was further concerned by the portrayal of what appeared to be fast and dangerous driving. Code rule 11.9.1 states that “no advertisement may encourage or condone dangerous, inconsiderate or irresponsible driving”. ASSESSMENT The BACC believed that although the advertisement was for an alcohol brand, there was no suggestion that the driver had been drinking. If there had been, it would not have been approved for broadcast. As to the driving sequence itself, it was filmed with a zoom effect to enhance tension and to give the impression of fast action. However, the BACC did not think the act of braking to avoid the cat implied the driver was speeding. The advertiser said a TVR sports car was chosen for its stylish image rather than to imply speed. And the open top model allowed a good view of the driver. The commercial did not show the driver speeding but merely taking evasive action to avoid the cat. The ITC had some reservations that an advertisement for alcohol should feature a fast car that was apparently being driven without due care and attention. However, on this occasion, it agreed there was no suggestion that the driver had been drinking and did not judge the commercial was in breach of the ITC Code in this respect. Nevertheless, it reminded the BACC that any advertisement for alcohol featuring driving sequences should be given careful consideration. ISSUE 4 The ITC judged that the sequence where the driver brakes to avoid the cat portrayed dangerous driving practice and did not agree that it merely showed somebody taking evasive action. The driver's decision to brake suddenly caused the car to skid dangerously for a length of time which suggested the car was being driven too fast, this was reinforced by sound effects. The ITC therefore required the advertisement should not be shown again in its current form. CONCLUSION Complaint not upheld but staff intervention Breach of ITC Code 11.9.1. HARMFUL COMPLAINTS FROM BACKGROUND Inappropriate Scheduling Scottish TV 1 viewer An advertisement for Lambrini, a sparkling wine, was shown during The Crocodile Hunter Diaries on Scottish TV. A viewer complained that although the programme was not shown as part of Children‟s ITV, it was promoted in it. He therefore felt it was inappropriate to schedule an advertisement for alcohol during a programme that was, as a result of the CITV promotion, likely to attract a large child audience. ITC rules require that products with an „ex-kids‟ timing restriction, like alcohol, should not be shown in programmes with a particular appeal to children. Post-transmission data showed that this programme had attracted a high proportion of child viewers. Carlton Sales, which schedules breaks for Scottish TV, explained that its predicted ratings profile had not anticipated such a large child audience and therefore the centre break was not restricted. It appreciated that the programme had been promoted during CITV and that this seemed to have had an effect on the size of the children's audience but added that it would not normally be aware of such promotions. The ITC judged the decision to promote The Crocodile Hunter Diaries during CITV was clearly aimed at attracting a child audience. A high child audience might in any case have been expected, given that it followed CITV The ITC advised Carlton to take steps to ensure that errors of this kind did not occur in future. ISSUE ASSESSMENT CONCLUSION Complaint upheld. Breach of ITC Code Rule 7.3.7. MISLEADING Carlton Television Sales Carlton Television COMPLAINTS FROM BACKGROUND 1 viewer An advertisement for Carlton Television Sales promoting the affordability of television advertising gave an 08706 telephone number to call for further information and stated "calls charged at local rate". A viewer pointed out that telephone numbers beginning with 08706 were charged at national rate. ISSUE 5 ASSESSMENT Carlton admitted that calls to the advertised number were charged at national rate and that the reference to local rate in the advertisement was a mistake. It apologised for the error and confirmed that the advertisement had been withdrawn, adding that an amended version would be on air shortly. The ITC noted that Carlton had removed the advertisement from air but nonetheless judged that it was misleading at the time of broadcast. Complaint upheld. Breach of ITC Code Rule 5.3.1. CONCLUSION MISLEADING JD Sports The TV Department Limited COMPLAINTS FROM BACKGROUND 1 viewer An advertisement for high street sports shop JD Sports stated that its sale was due to start on Boxing Day. A viewer visited his local JD Sports on Boxing Day but found it was closed. He complained that the advertisement was misleading. BACC explained that JD Sports had failed to inform the production company responsible for its advertising that only two thirds of its stores would be open on Boxing Day for the first day of the sale. Consequently BACC had approved the advertisement on the understanding that all stores would be open. The production company assured BACC that it would have advised JD Sports of the need to include a qualifying statement in its advertising if it had been aware that only selected stores were opening. The ITC noted the BACC's comments but nonetheless judged that the advertisement was misleading at the time of broadcast. Complaint upheld. Breach of ITC Code Rule 5.2.3. ISSUE ASSESSMENT CONCLUSION MISLEADING Specsavers - 2 for 1 offer Specsavers Optical Group COMPLAINTS FROM BACKGROUND 2 viewers An advertisement for Specsavers promoted an offer for two pairs of single vision, bifocal or varifocal glasses for the price of one. On-screen text stated "£75 range and above. Conditions apply. Details in store". A viewer complained the advertisement had failed to mention that the second pair of glasses were only completely free if they came from the Specsavers range. She had expected to be able to choose them from the same designer range as the pair she was intending to buy. However, she was told that opting for a second pair of frames from the designer range would cost £30 - the difference between the price of the designer range (£129) and the top price Specsavers standard range (£99). BACC explained that the advertiser had failed to inform it of the need to pay the £30 difference between the designer range and the Specsavers range when it approved the commercial. In its defence, the advertiser felt "conditions apply" was sufficient to cover the limitation. ISSUE ASSESSMENT 6 The ITC considered that because the advertisement specifically stated "£75 range and above", viewers would expect to be able to get their first pair and second free pair from the same range. The fact that customers would have to pay the difference in cost between one range and another to get their "free" pair was a significant condition that should have been made clear in the advertisement. It therefore judged the advertisement was misleading and required that it should not be shown again in its current form. CONCLUSION Complaints upheld. Breach of ITC Code Rule 5.2.3. MISLEADING Simply Home Phone Dome COMPLAINTS FROM BACKGROUND Staff monitoring An advertisement for the Phone Dome, a mobile phone accessory which claimed to offer "significant protection from radiation", was shown on Simply Shopping. It warned viewers of the dangers of using mobile phones and asked "will you play with fire?", "will you take a chance?" and " are you using a health hazard time bomb?". It also contained testimonials from people who claimed that using the Phone Dome had eliminated the headaches and pains in their hands and hips they previously got when using their mobile. The ITC asked Simply Shopping to provide substantiation for the claims made and to explain how it complied with Note 1 of ITC Code Rule 6.4 which states "any appeal to fear should be justified and proportionate". Simply Shopping provided substantiation from its suppliers. This included scientific test results, Department of Health guidelines on the use of mobile phones and testimonial letters from people who claimed to have benefited from using the Phone Dome. It told the ITC that the advertisement was no longer on air. The Department of Health (DoH) information said that, based on current research evidence, "exposure to radio waves below the levels set out in international guidelines (which all mobile phones sold in the UK adhere to) do not cause health problems for the general population". It also recommended that mobile phone users adopt "a precautionary approach" to using their phones until more research findings became available. The ITC considered that this evidence appeared to counter the claims made in the advertisement and did not judge the test results or testimonials that were also provided offered adequate substantiation to support those claims. It reminded Simply Shopping that a testimonial could not be regarded as substantiation for a factual claim (ITC Code Rule 5.4.4). Simply Shopping failed to comment on whether it felt the advertisement could appeal to fear. However, the ITC considered that phrases such as "health hazard time bomb" and " play with fire" were emotive and particularly inappropriate given the level of public concern about mobile phone safety and the DoH statement that there was insufficient evidence to prove the phones caused health problems. The ITC noted that the commercial was no longer on air and required that it should not be shown again in its current form. CONCLUSION Breach of ITC Code Rules 5.2.1, 5.4.4 and 6.4. ISSUE ASSESSMENT 7 MISCELLANEOUS Tarot advertising Teletext/ MTV Text COMPLAINTS FROM BACKGROUND Staff monitoring With some exceptions, the TV advertising of products or services concerned with the occult has been prohibited for many years. In November 2002, the ITC published a redeined exception to the relevant rule (10.3) reflecting advice about vulnerable viewers. This allowed advertising for pre-recorded tarot-based predictions which are clearly presented as simply for entertainment and which would be unlikely to encourage people to change their behaviour in any significant way. The letters to the broadcasters explaining the exception also granted a period of grace so that the advertising could be brought into line. ISSUE ITC monitoring found examples of advertising for pre-recorded tarot "readings" on Teletext (Channels 3, 4, & 5) and on MTV's text service which appeared to breach 10.3 by not following the terms of the exception. Both broadcasters declared that they had no record of receiving the letter about the exceptions and had not understood that the ITC's policy in this area had changed. In view of these broadcasters' generally good compliance track record, the ITC accepted their defences and extended the period of grace. The broadcasters brought all the advertising into line within that extended period. No further action ASSESSMENT CONCLUSION MISCELLANEOUS COMPLAINTS FROM BACKGROUND Scheduling of Advertising Carlton TV Staff monitoring During the investigation of complaints about an advertisement for Yahoo Personal Finance (see ITC Television Advertising Complaints Bulletin 5, 23 December 2002), the ITC required the BACC to inform licensees that this commercial was to be suspended pending the outcome of the investigation. The following week, during routine monitoring, the ITC saw the advertisement on ITV1 in the Carlton region. The BACC confirmed that it had informed all licensees - including Carlton of the suspension. It had done this by means of a telephone call on Friday 22 November and again on Monday 25 November, and an email – sent automatically when the status of an advertisement is changed on the computer system that BACC shares with its client broadcasters – on 26 November. Carlton was unable to locate any record of being told of the decision concerning Yahoo, however. Although it was unclear which party was at fault, the ITC found Carlton - its licensee - in breach of the Code of Advertising Standards for transmitting an advertisement which the ITC had required to be suspended. It advised Carlton of the need for reliable procedures to avoid such a situation happening again. ISSUE ASSESSMENT CONCLUSION Breach of ITC Code Rule 6.6. 8 Summary of Other Complaints Advertisements for the products or services listed below attracted complaints which after preliminary assessment, did not raise issues of substance requiring further investigation. These included complaints repeating points already considered and covered in previous summaries, as well as isolated expressions of personal opinion or experience which did not call into question the conformity of the advertisements with the requirements of the ITC Code of Advertising Standards and Practice. Product or Advertisement Number of Complaints 1 1 1 1 1 1 1 1 1 2 1 1 2 1 1 2 1 1 2 1 1 HARMFUL Batchelors Cup a Soup (Opera) Boots Clearasil - Overdressed DETR - Rear Belts 2001 Dettol - toy truck Film Trailer - The Ghost Ship Fireplace World Ford Fiesta - Measles Glade Touch n Fresh McDonalds - Corporate Mind, Body, Spirit Magazine More Th>n - Royal Sun Alliance Mormon Book - Hands Optimax Laser Eye Treatment Parazone Flushable Wipes Pot Noodle - Red light District Shreddies Teacher Training - can you? Time Life - Songs For Worship CD's Time Life Music - Songs 4 Worship Wotsits - Flikka 9 Product or Advertisement MISCELLANEOUS Daily Mail DETR - Think Speed Muller Light - Steward Nescafe - Frothy Coffee NSPCC - hospital scene/baby Pot Noodle - Aunty Jane Sky Trailers/Promotions Time Life - Songs For Worship CD's Number of Complaints 1 1 1 1 1 1 1 3 Product or Advertisement MISLEADING Abbey National - trade in Airtours Direct - TEXT Anchor Butter AOL - Broadband Auction World Product Axa Investments B&Q Barrett Homes Benylin Active Response Best Direct Product Bid-up.tv Bid-up.tv product British Gas - boiler engineers British Gas - Delete BT Broadband - burst pipe BT Broadband - Pig Power BT Internet - Anytime BT Openworld Narrowband Cancer Research UK - Photo Mirror Centre Parcs Churchills Mobility Aids - The COI - Child Tax Credit COI/Inland Revenue - Tax Credit Cornhill Insurance - Cashback Daily Express - Easy Jet offers Daz - Burger King Offer DETR - Think Speed DFS - Sale End Harrods Sale Hyundai - relationships Ideal World HS - Product Intelligent Finance - Boat Number of Complaints 1 1 1 1 2 1 1 1 1 1 1 1 1 1 4 1 1 1 1 4 1 1 1 1 1 1 6 1 1 1 1 1 10 International Technology Exchange Kwik Travel - TEXT Max Spielmann WOW Camera Moben Kitchens Mormon Book - Hands NTL - Phone & Cable Lines Optimax Laser Eye Treatment Orange Picture Messaging P & O Stena Line Pizza Hut - £9.99 family deal Powergen QVC Product Safestyle UK Scottish Executive - Domestic Screenshop product Shell - global Sky Sports - Season Ticket SMA Progress Milk SMS Joke of the Day Teacher Training - Tattoo Telebrands - Roll A Hose TellSell Product Time Life Music - Classic Country Whale & Dolphin Conservation Society 1 1 1 1 1 1 1 1 1 1 2 1 2 1 1 2 1 1 1 1 1 1 1 1 Product or Advertisement OFFENSIVE AA Breakdown Alpen Bars Burger King - Triple Burger £1.99 Carphone Warehouse - not just for xmas Clairol Herbal Essences Clear Off Holidays COI - Child Tax Credit COI - road tax evasion COI/Inland Revenue - Tax Credit DETR - Rear Belts 2001 Energy Efficiency - Bad Boiler Film Trailer - The Ghost Ship Film Trailer - Two Weeks Notice Ford Fiesta - Measles Fosters - robot Gala Bingo - Handcuffs Glade Touch n Fresh Guardian - World Cup Cricket Number of Complaints 1 87 1 1 1 4 2 1 1 2 1 1 1 1 2 1 1 7 11 Honda - pecking order John Peters: Half Off Sale John Smith - Mum Kelloggs Fruit Winders Kleenex Tissues Lunn Poly - Getaway 2003 McCain - Rosti Mormon Book - Hands Movelat Relief Muller Light - Steward Naturally Close Lingerie Catalogue NCDL Nokia - Poker Oriental Express Pot Noodle - Aunty Jane Pot Noodle - Red light District RSPCA - kitten Safestyle UK Sainsburys Healthy Eating - Dog Sanex - kissing with confidence Sharwoods - experiment Sure Deodorant The Bee Gees - 40 Of Their Greatest Hits Unknown Product Vauxhall Astra - Rollercoaster Virgin Mobile - Wyclef Soap Walkers Wotsits - School scene WKD - New Girlfriend WSPA - Dancing Bear 1 2 3 1 2 1 1 1 1 2 2 1 1 1 1 4 4 1 13 1 2 2 1 3 1 4 2 5 1 Product or Advertisement UNKNOWN Volkswagen Polo - Whatever Number of Complaints 1 12 There were also complaints of a generic character referring to the following matters :Product or Advertisement Number of Complaints 1 1 4 1 MISCELLANEOUS Amount of Advertising Miscellaneous comments Noise Scheduling of Advertising Product or Advertisement MISLEADING Miscellaneous comments Number of Complaints 1 Product or Advertisement OFFENSIVE Miscellaneous comments Number of Complaints 2 Product or Advertisement UNKNOWN Amount of Advertising Noise Number of Complaints 1 1 13 Analysis COMPLAINTS DETERMINED IN FEBRUARY Number of complaints Number of advertisements referred to HARMFUL MISLEADING OFFENSIVE MISCELLANEOUS UNKNOWN 28 76 585 19 3 711 (0) (2) (0) (1) (0) (3) 24 58 53 13 3 151 (0) (2) (0) (1) (0) (3) Number of advertisements about which complaints were upheld wholly or in part 4 (0) 3 (0) 6 (0) 1 (0) 0 (0) 14 (0) YEAR TO DATE 2003 Number of complaints Number of advertisements referred to HARMFUL MISLEADING OFFENSIVE MISCELLANEOUS UNKNOWN 41 256 822 47 7 1173 (0) (7) (0) (1) (0) (8) 37 172 161 34 7 411 (0) (7) (0) (1) (0) (8) Number of advertisements about which complaints were upheld wholly or in part 5 (0) 15 (1) 13 (0) 4 (0) 0 (0) 37 (1) The numbers in brackets indicate Text advertisements. They are extracted from, not additional to, the overall numbers. 14