The IPP stands for Intermediaries and Platforms Principles, an initiative intended to develop a framework of following and applying CAP guidance and rules; Intermediaries being agencies and ad-buying platforms, and Platforms being the likes of YouTube, Instagram, Twitch, etc. The IPP currently deals with programmatically targeted or served ads to audiences.
It’s important to note that sponsorships, affiliate programmes, and incentivised reviews do not fall under the IPP at present because the Platforms (and some of the Intermediaries), are not part of the "supply chain".
For those not permanently dialled into 'RegulationFM', the 6 Principles of the IPP are…
Participating companies will:
- Bring to advertisers’ attention* in a reasonably prominent way, the requirement for advertisements aimed at a UK audience to comply with the CAP Code.
*or, where they are acting for advertisers, agencies’ attention.
- Ensure their advertising policies and applicable contractual terms require advertisements aimed at a UK audience to comply with the CAP Code.
- Assist the ASA in promoting the public’s and advertisers’ awareness of the ASA system.
- In relation to the requirement for advertisers to minimise children’s and young persons’ exposure to ads attracting an age targeting restriction* under the CAP Code (and where such ads are permitted by the participating company’s own policies), take reasonable and appropriate measures to make advertisers** aware of: the tools or controls that can be used on the service to support advertisers to comply with the requirement; who provides and/or selects the tools/controls; and, who is responsible for activating and controlling them.
*Guidance to this Principle lists ads for products which must not be directed at children (under 16s) and/or young people (aged 16 or 17) through the selection of media or the context in which they appear. 22
**or, where they are acting for advertisers, agencies
- On receipt of a relevant notice from the CAP Compliance function, act swiftly to remove a non-compliant ad that is the subject of a specific breach of the CAP Code as determined by, or directly related to, a published ASA ruling, in instances where the advertiser fails to appropriately amend or withdraw its non-compliant ad.
- On receipt of a relevant notice from the CAP Compliance function, act swiftly to remove a non-compliant ad that is indisputably a prima facie breach of the CAP Code, in instances where the advertiser fails to appropriately amend or withdraw its non-compliant ad.
- Respond in a timely way to reasonable requests for information from the ASA in relation to advertisers’ use of the company’s services, to assist investigation of a suspected breach of the CAP Code, in instances where the information cannot be obtained from the advertiser*.
*or, where appropriate, their agency
Interim report - more to come
This was an interim report of the first 6 months of the trial. A full report will be published in Q3 2023.
While the IPP is taking aim at programmatic ads served by platforms and purchased as inventory by the advertiser, the classification of what constitutes an ad will eventually put all ad compliance in scope, but here they're dealing with the easier type of ad to address.
Before the ASA can implement the principles for direct influencer marketing activities, there are four considerations to address…
- Removal of non-compliance advertising would likely mean the removal of a channel's content for that sponsorship entirely, which means taking it down for all audiences, not just those in the UK.
- Given the nature of live, long, and short-form video, the perceived 'damage' would likely already been done within the first 7-10 days of the content's availability, and it's unlikely 6 a) and b) would be enacted during this time.
- There are no advertising credits to be offered for CAP awareness-building or sanctioning offenders, given they operate outside Platform control.
- Most significantly, Principle 4 deals with inappropriately targeting children with unsuitable advertising, or advertising unsuitable products. Above all else, this is where we will see the most focus internationally. It's the aligning mantra for all regulators and legislators, and will likely produce the swiftest, most impactful and costliest action against advertisers.
Further to point 4, and as noted in the 2020 COPPA ruling against YouTube's DanTDM, creators do not have realtime access to viewer ages, as would be the case for the platform serving an ad. Or similarly, the 2023 ASA ruling against SurfShark and TomSka & Friends, which arguably can only look at their own channel viewer demographics to determine that 'enough' of a percentage are of a suitable age for the advertising.
For the vast majority of those conducting direct influencer marketing campaigns without the resources or expertise of an agency, the 6 principles will unfortunately fall wide of both the Intermediaries or Platforms.
Once again, the responsibility falls on brands to do their due diligence. Some audience demographic information will be available through services like Upfluence and Tagger Media's tools, but budgets may not allow for access to those platforms.
The alternatives are to go back and watch channels' historic videos, which is massively time consuming. Or you can use RippleXn to quickly review a few 100 hours of content quickly for all the include/don't include words and phrases to generate your shortlist of potential partners, then reach out to them directly for audience demographic information.
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