People’s Postcode Lottery escapes ASA reprimand over Emma Willis TV ad
Regulatory body finds campaign starring TV and radio presenter did not breach the CAP code by having a strong appeal among under-18s
The Advertising Standards Agency (ASA) has ruled that a TV advert by the People’s Postcode Lottery featuring TV and radio presenter Emma Willis in November 2023 did not breach regulations in appealing to under-18s.
The advert featured her sitting in a dressing room, with the logo for the ITV talent show The Voice visible in the dressing room mirror alongside a large V on the wall next to the mirror.
In the advert, Willis said: “Right now, there’s only one question you should be asking: is your door in the draw?”
Willis was then seen walking through a suburban neighbourhood before announcing: “People’s Postcode Lottery is giving away its biggest ever prize fund, £17.3m – simply sign your door up with your postcode to see what it could win you. With a share of £17.3m to be won, there really is only one question to ask yourself: is your door in the draw?”
A complaint challenged whether Willis held a strong appeal among under-18s and, so, had flouted the CAP advertising code.
The social lottery operator acknowledged that Willis was a presenter on The Voice Kids, which featured under-18s, but it did not believe that the programme itself held a strong appeal to children and that Willis herself was not a children’s TV presenter.
The People’s Postcode Lottery also supplied data from the Broadcaster’s Audience Research Board (BARB) for The Voice and The Voice Kids and four other TV programmes that Willis presented. Parent company Postcode Lottery Ltd said that the data showed the programmes did not have a strong appeal to children.
Postcode Lottery Ltd also supplied a breakdown of the demographics for Willis’ social media followers on Facebook and Instagram. On Instagram, just 0.7% of her followers were aged between 13 and 17, while on Facebook, 0.2% of Willis’ followers were within that age range.
The firm was unable to provide a breakdown of Willis’ X followers but believed that this platform would be similar Facebook and Instagram, and that what she posts on X is adult-orientated and promotes her upcoming TV appearances, as well as ads for adult-focused brands.
Postcode Lottery Ltd also pointed to previous ASA rulings in which individuals whose profiles were similar to Willis’ were determined not to have strong appeal with minors.
Advert clearing service Clearcast said that while Willis was a widely recognisable individual, it was satisfied by the BARB data and her social media follower breakdown, which showed that Willis did not have a large under-18 following.
The ASA found that throughout Willis’ career she presented several programmes primarily targeted at adults, including Big Brother and a Sunday morning radio show on Heart Radio, but due to her association with these programmes ending in 2018, they were no longer relevant in the context of this advert.
The watchdog also examined some of Willis’ more recent presenting roles, including The Circle from 2019 to 2021 and Cooking with the Stars from 2021 to 2023, and ruled these were adult-orientated and likely would not strongly appeal to children.
Regarding The Voice and The Voice Kids, it was decided that due to the shows being broadcast at 7:30pm and 8pm, respectively, on Saturday evenings these time slots would be considered suitable for family viewing. Willis herself referenced that her children watched the shows.
Additionally, the children’s news programme Newsround published several articles about the talent shows.
The ASA also concluded that because the ad prominently featured The Voice logo, any underage viewer of the ads and TV show would recognise Willis as the presenter.
Despite this, the advertising regulator concluded that the talent shows did not give Willis a strong appeal to under-18s.
The ASA then looked at the evidence around Willis’ social media following that was provided and drew the same conclusion.
Wilis’ other commercial partnerships were also examined, including those with Gilette Venus, Oral B, Marks & Spencer and Absolute Collagen, and determined that these adult-focused brands would not strongly appeal to children.
Due to these findings, the ASA did not consider Willis to have a strong appeal to under-18s and therefore found People’s Postcode Lottery to not be in breach of the CAP code.