WHO'S FEEDING THE KIDS ONLINE? - Digital Food Marketing and Children in Ireland - Report prepared for the Irish Heart Foundation 2016

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WHO'S FEEDING THE KIDS ONLINE? - Digital Food Marketing and Children in Ireland - Report prepared for the Irish Heart Foundation 2016
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WHO’S FEEDING
THE KIDS ONLINE?
Digital Food Marketing and Children in Ireland

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Report prepared for the Irish Heart Foundation – 2016       Irish Heart Foundation
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                                                                                  Who’s Feeding
                                                                                  The Kids Online?
                                                                                  Digital Food Marketing and Children in Ireland

                                                                                  Dr. Mimi Tatlow-Golden Ph.D.
                                                                                  With Lynne Tracey BA, FIAPI and Dr. Louise Dolphin Ph.D.

                                                                                  Report prepared for the Irish Heart Foundation – 2016

Who's Feeding the Kids Online? | Digital Food Marketing and Children in Ireland
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                                                                                                                 Table of Contents
                                                                                                                 Summary                                                                                                                      4
                                                                                                                        Recommendations                                                                                                       6
                                                                                                                 1. The web of influence: Marketing food to children goes online                                                              7
                                                                                                                        1.1 Food marketing and children’s rights                                                                              8
                                                                                                                        1.2 The limits of current regulation                                                                                  9
                                                                                                                        1.3 Digital media, children and marketing                                                                         10
                                                                                                                        1.4 Understanding the effects of digital marketing and children’s ability to resist it                            11
                                                                                                                        1.5 Identifying digital food marketing seen by children: An imbalance of access and power                         12
                                                                                                                        1.6 Who’s responsible? An issue of choice, or of children’s rights?                                               13
                                                                                                                 2. On the homepage: Websites of top food and drink retail brands                                                         15
                                                                                                                        2.2 Advergames and apps                                                                                           18
                                                                                                                        2.3 Appealing to families                                                                                         19
                                                                                                                        2.4 Food and drink website features appealing to teens                                                            20
                                                                                                                        2.5 Competitions                                                                                                  22
                                                                                                                        2.6 Summary                                                                                                       24
                                                                                                                 3. On Facebook: Food brand Pages popular among young teens                                                               25
                                                                                                                        3.1 Brands with the greatest ‘reach’ in Facebook among users aged 13 and 14 years in Ireland                      27
                                                                                                                        3.3 Analysing brand Pages: Brand Page ‘likes’ and brand post ‘likes’ and shares                                   28
                                                                                                                        3.4 Analysing brand Pages: Coding the brand posts for marketing techniques                                        30
                                                                                                                        3.7 Postcript: What do children actually see in their Facebook News Feeds?                                        38
                                                                                                                 4. Who’s feeding the kids online: What do parents know?                                                                  39
                                                                                                                        4.1 Exploring parents’ views                                                                                      40
                                                                                                                        4.2 Participating parents                                                                                         41
                                                                                                                        4.3 Food decisions at home and eating with friends                                                                41
                                                                                                                        4.4 Parents’ awareness of and views about advertising                                                             42
                                                                                                                        4.5 Talking with their teen about advertising and food ads                                                        42
                                                                                                                        4.6 Parents’ responses to online food marketing                                                                   43
                                                                                                                        4.7 After viewing the ads                                                                                         47
                                                                                                                        4.8 Summary                                                                                                       48
                                                                                                                 5. Digital food marketing to children and young people: The way forward                                                  49
                                                                                                                 6. Recommendations                                                                                                       53
                                                                                                                 References                                                                                                               56
                                                                                                                        Endnotes                                                                                                          59
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www.irishheart.ie                                                                                                Who's Feeding the Kids Online? | Digital Food Marketing and Children in Ireland                       Irish Heart Foundation
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Summary
                                                                                                                                                                                                                        @
                                                                                                             Although little marketing directed
                                                                                                             at young children on food brand
                                                                                                             websites was found, there was a
                                                                                                             strong focus on teen-appealing
     Obesity in children and young people is a global health challenge. The widespread marketing of
                                                                                                             content on websites and on
     unhealthy foods (food and non-alcoholic drinks high in fat, sugar and salt, or HFSS) plays a causal     social media, using powerful
     role in unhealthy eating and obesity. Food and eating is typically presented as an issue of ‘choice’.   engagement-, emotion-, and
     However, this disregards the fact that current obesogenic environments use many tactics to              entertainment-based tactics. Parents
                                                                                                             of young teens in Ireland are largely
     promote unhealthy foods, interfering with people’s ability to make good choices.
                                                                                                             unaware of this. There are clearly
                                                                                                             challenges presented by national
                                                                                                             regulation of global media, yet
Ireland restricts HFSS broadcast
                                                                                                             any site where young people enter
advertising to under-18s on TV
                                                                                                             their age to register could switch       Facebook Food brand Pages               Parents are unaware of
and radio, but has not yet tackled
                                                                                                             off HFSS advertising to under-18s        popular with 13-14 year                 digital food marketing and
regulation of digital marketing.
                                                                                                             immediately.                             olds: Engagement, emotion,              its engagement techniques.
Children in Ireland are increasingly
active on digital media, with most 9                                                                         Here, brief synopses of each section     entertainment                           They consider many of them
to 16 year olds now going online via                                                                         of the study are presented, followed     In Facebook, all the food/drink         misleading and exploitative
a smartphone. Digital media have                                                                             by the recommendations.                  brand Pages with the greatest           Parents of 13-14 year olds were
fundamentally changed marketing,                                                                                                                      reach among users aged 13-14 in         selected from a large online panel
and evidence from marketers
                                                                                                             Websites of top retail food              Ireland are for brands that feature     to reflect a range of demographics
and digital platforms indicates                                                                              brands in Ireland: 1 in 5 very           HFSS products. They included            in Ireland and 33 took part in an
that online methods increase the                                                                             appealing to teens                       major international brands (e.g.,       online interactive interview. They
impact of marketing, including                                                                               Other jurisdictions report               Coca-Cola) and local Irish ones         had generally positive attitudes to
for unhealthy foods. Digital                                                                                 widespread engaging and                  (e.g., Tayto). Some brands posted       advertising, and though two-thirds
marketing can target children using                                                                          immersive children’s sections, but       updates on their Pages infrequently,    felt teens should not view HFSS
sophisticated analytics, as opposed                                                                          on 73 websites of the top retail         less than once a week, but others       food advertising, they were largely
to broadcast TV advertising which                                                                            food brands in Ireland, just 1 in 10     posted more than once daily. Brands     unaware of and indifferent to the
can only rely on a scattergun effect.                                                                        had some child-directed content,         actively sought user engagement,        issue of digital food marketing,
                                                                                                             much of it at most mildly engaging.      seeking ‘likes’, tags, comments,        and almost none knew how brand
Whereas anyone can inspect ads
                                                                                                             In informal discussions, digital         and photos, and providing many          content reaches Facebook users’
that are shown on TV, the targeted
                                                                                                             marketers in Ireland reported that       links and hashtags (#). In addition     News Feeds. They conceived of
nature of digital marketing means
                                                                                                             in Ireland’s HFSS regulatory context,    to bold graphics and strong visuals,    ads online as requiring opening,
that parents and policymakers are
                                                                                                             directing food marketing specifically    they featured competitions, had         or clicking to skip. However, once
unaware of who is feeding our kids
                                                                                                             at young children is now considered      a strong emphasis on humour,            parents had viewed examples of
online.
                                                                                                             unethical, and that therefore they       invoked fun and ‘special days’,         food marketing from digital media,
This study examined:                                                                                         target parents of young children         and linked to entertainment and         their attitudes shifted. They said
1. Content appealing to children                                                                             instead. Notably, however, one in        events (current movies, music, TV,      they had been unaware of how
   and young people on websites                                                                              five websites, almost all for items      festivals). Over a quarter of the 354   subtle digital food marketing is
   of top food and drink retail                                                                              high in fat, salt or sugar (HFSS), had   brand posts analysed did not show       and felt that great maturity would
   brands in Ireland                                                                                         content directed at or appealing         food, packaging or a brand logo,        be needed to resist. They voiced
                                                                                                             to older children or teens, focusing     indicating a shift to more subtle       particulary strong concerns about
2. Marketing techniques on                                                                                   on teen activities, entertainment        promotional strategies that are less    celebrities and sporting heroes
   Facebook Pages of food brands                                                                             and sporting celebrities, and            easily identified as advertising.       engaging in what they considered
   that have the highest reach                                                                               competitions with entertainment-,                                                misleading advertising for unhealthy
   among young teens, the first                                                                              media- and sport-based prizes.                                                   foods. When shown prompts from
   such study of which we are                                                                                Not included in this analysis, and                                               ads to ‘tag’ friends in Facebook, two-
   aware                                                                                                     requiring systematic examination,                                                thirds of parents used terms such
3. Parents’ awareness of digital                                                                             were video games, apps in app                                                    as immoral, dishonest, exploitative,
   food marketing to their children                                                                          stores, fast food websites, and                                                  or should be banned. After viewing
   in an online, two-stage survey                                                                            websites for international products                                              the marketing examples, three-
   with digital marketing examples                                                                           of appeal to children in Ireland.                                                quarters of parents were strongly
   and open-ended response                                                                                                                                                                    against teens receiving digital HFSS
   options.                                                                                                                                                                                   marketing.

Who's Feeding the Kids Online? | Digital Food Marketing and Children in Ireland                                                                                                                                Irish Heart Foundation
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Recommendations
1. Recognise children’s rights to                 5. Disrupt the language of ‘choice’       must be grounded in careful, child-
participation - but also to health                and ‘responsibility’                      centred research, as eating unhealthy
and protection                                    Obesogenic environments push              foods currently often forms part of
Children have the same rights online              unhealthy choices through food            children’s identity as separate from
as they do offline. These include
rights to participate in social life and
                                                  promotion, pricing and availability.
                                                  Framing families’ and children’s
                                                                                            the adult world in Ireland and across
                                                                                            Europe, so general ‘healthy eating’       1. The web of influence:
to have their voices heard, but also              eating as purely a matter of ‘choice’     messages from adults may even
                                                                                            encourage less healthy practices.
                                                                                                                                      Marketing food to children goes online
rights to health and to have their                disregards the impact of obesogenic
                                                                                            Children have also been found
best interests considered. Therefore,             environments on children, young
                                                                                            to attend less to marketing for
ways need to be devised to ensure                 people and parents – and also
                                                                                            healthier items, although this may
that under-18s can participate safely             disregards the choices made by food
                                                                                            depend on the nature of the ads.
online – without being subject to                 companies to promote such items to
                                                                                            For example, what would the effect
targeted marketing for products that              children, parents of young children,
                                                                                            be if the ‘heroes of the young’ (such
have been demonstrated to have a                  and teens.
                                                                                            as YouTube vloggers, and sporting
negative effect on their health and
                                                  6. Prohibit ‘heroes of the young’         stars), who currently promote
well-being, and without having their
                                                  from marketing HFSS products              unhealthy foods, were instead to turn
data harvested and resold online.
                                                                                            to promoting healthy items? Finally,
                                                  To protect children and young
2. Extend existing regulation for                                                           it is important to note that social
                                                  people, ‘heroes or heroines of the
broadcast media to all digital media                                                        marketing for healthier eating alone
                                                  young’ – celebrities in entertainment,
                                                                                            is not the answer. It cannot replace
Statutory regulation in Ireland has               sport and other domains – are
                                                                                            the need for regulation, as public
established the principle of no HFSS              prohibited from marketing any
                                                                                            health cannot match the marketing
broadcast advertising to under-18s.               alcohol advertising in Ireland (ASAI,
                                                                                            budgets of major food companies.
The same should apply to social                   2015). This exclusion should be
media and all other digital platforms.            extended to all HFSS marketing.           9. Equalise access to information
                                                                                            about digital HFSS marketing
3. Identify international options for             7. Inform young people, parents and
                                                                                            Media platforms, marketers and
ending HFSS food promotion                        policy makers about digital food
                                                                                            food brands have extensive access
Obesity has become a global health                marketing.
                                                                                            to data about children, and they
challenge, and tackling obesogenic                The ‘Internet safety’ issue tends to
                                                                                            engage in extensive research on
environments – of which HFSS                      push marketing into the background        them without independent research
marketing is a part – must become                 when children’s digital participation     ethics governance. In contrast, those
a global priority, particularly HFSS              is discussed, but individually targeted   concerned with public health cannot
marketing to which children and                   marketing is a well-being issue           access these data. Yet – in an era of
young people are exposed.                         of itself – and is linked to privacy      targeted and personalised marketing
                                                  concerns through the collection of        – it is essential that researchers
4. Close loopholes in current                     personal data. Young people, parents      concerned with children’s well-being
regulations                                       and policymakers need information         find ways to systematically examine
As in other jurisdictions, Ireland’s              on privacy issues and how children’s      children’s engagement with digital
statutory regulation lacks                        data is used to target them, their        food marketing in Facebook and
effectiveness, as it is limited to                friends and their families. They also     beyond (e.g., Instagram, Snapchat,
children’s programming on pre-6pm                 need to be informed about the             video games that deliver in-game
TV, and is governed by one of the                 effectiveness of emotional marketing      ads, branded food and drink
most lax Nutrient Profiling models                approaches that function through          apps appealing to children and
by international standards (UK                    implicit ‘stealth’ persuasion.            more). Which children are more
Nutrient Profiling; UK NP). Regulatory                                                      likely to engage? In what way do
loopholes should be closed, and UK                8. Consider the potential of ‘social
                                                                                            they do so? What effect does this
NP replaced with a simpler, stricter              marketing’ for healthier habits
                                                                                            have? Answering these questions
system such as the WHO European                   Social marketing seeks to change          is essential. In the interests of
Region 2015 Nutrient Profiling (WHO               a group’s perceptions of what is          children’s rights to health, protection
Euro-NP) which has rapidly gained                 normative behaviour. It is often          and participation online as well
acceptance across WHO Regions                     recommended to prompt healthy             as offline, this imbalance of access
worldwide.                                        eating. However, any such approach        needs to be equalised.

Who's Feeding the Kids Online? | Digital Food Marketing and Children in Ireland                                                                                                Irish Heart Foundation
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1. The web of influence: Marketing food to                                                                                          1.2 The limits of current regulation
                                                                                                                                    Some governments have responded
children goes online                                                                                                                to calls for marketing restrictions,
                                                                                                                                    implementing regulations of varying
                                                                                                                                    impact to limit children’s exposure
     In Ireland, one in four children is overweight or obese. Current World Health Organisation (WHO)                               to marketing for unhealthy foods
     predictions are that in 2025, over 80% of aduts in Ireland will be overweight or obese, the highest                            in Europe, Asia, South America
     proportion in the WHO 54-country European Region (UK Health Forum/WHO 2015). Tackling the                                      and the Middle East (see World
                                                                                                                                    Cancer Research Fund [no date]).
     underlying causes of obesity in Ireland is a critical issue for children’s rights, health and well-being.
                                                                                                                                    In 2013, Ireland established the
                                                                                                                                    important principle that items
                                                                                                                                    high in fat, salt or sugar (HFSS)
                                                                                                                                    should not be advertised to
                                                                                                                                    under-18s on broadcast media (TV
                                                                                                                                    and radio), when the Children’s
                                                                                                                                    Commercial Communications Code
                                                                                                                                    update prohibited advertising
                                                                                                                                    HFSS products around ‘children’s
                                                                                                                                    programming’ (Broadcasting
                                                                                                                                    Authority of Ireland [BAI], 2013).

                                                                                                                                    Ireland’s broadcast ban, however,
                                                                                                                                    despite being a strong statement
                                                                                                                                    about protecting children and
                                                                                                                                    young people, has only been
                                                                                                                                    partially successful at reducing
                                                                                                                                    exposure to HFSS marketing.               with carrot sticks). The definition of   forms of digital marketing, rather
                                                                                                                                    The ban applies to ‘children’s            HFSS currently applied in Ireland,       than displacing effects of traditional
                                                                                                                                    programming’, when under-18s              the UK Nutrient Profiling model (UK      media such as television, instead
                                                                                                                                    form 50% or more of the audience,         NP; UK Department of Health, 2011)       magnify them, as described in
                                                                                                                                    and up to 6 pm – yet most of the TV       has been identified as lax compared      section 1.3.
                                                                                                                                    programming children and young            to other international systems
                                                                                                                                                                                                                       Currently digital marketing of
                                                                                                                                    people view does not meet these           (Scarborough et al., 2013). It permits
                                                                                                                                                                                                                       food to children in Ireland is
                                                                                                                                    criteria. As a result, even very young    marketing to children of foods with
                                                                                                                                                                                                                       subject to voluntary regulation by
                                                                                                                                    children in Ireland are likely to see     more than 10g sugar per 100g, or
                                                                                                                                                                                                                       the advertising industry’s Code
                                                                                                                                    over 1,000 unhealthy food ads on          drinks with artificial sweeteners,
                                                                                                                                                                                                                       (Advertising Standards Authority
                                                                                                                                    television a year under current           which do not pass recommendations
                                                                                                                                                                                                                       for Ireland; ASAI, 2015). Although
1.1 Food marketing and children’s rights                                                                                            regulations (Tatlow-Golden et al.,        for marketing to children under the
                                                                                                                                                                                                                       the Code defines children as those
                                                                                                                                    2016), and older children who watch       WHO Europe Nutrient Profile model
                                                                                                                                                                                                                       under 18, and states that marketing
Although eating habits and the                    which consulted with over 100            primacy of the child’s best interests.   more TV later in the day probably         (WHO, 2015).
                                                                                                                                                                                                                       should not ‘encourage an unhealthy
causes of obesity are complex                     WHO Member States (WHO, 2016).           This leads to the understanding, as      view substantially more.
                                                                                                                                                                              A final, major factor limiting the       lifestyle or unhealthy eating or
and are affected by many factors,                 Recently, the UN Special Rapporteur      the WHO Commission noted, that           Similar regulation gaps have been         effectiveness of current regulation      drinking habits’ (Rule 8.16), this
systematic reviews of research                    on the right of everyone to the          States have a ‘moral responsibility’     identified in the US and the UK,          in Ireland, and the one that has         is open to interpretation as no
have consistently found that food                 enjoyment of the highest attainable      to act in this regard (WHO, 2016).       and in the UK HFSS advertising has        provided the impetus for this report,    definition of unhealthy eating or
marketing plays an independent                    standard of physical and mental          The need to act to reduce food           shifted to general-view programmes        is that existing statutory regulations   drinking habits is given and no
causal role (Cairns, 2013; Cairns et              health has also done so (UN, 2014).      marketing has also recently been         viewed by many children (Boyland          only apply to broadcast media –          Nutrient Profiling system is applied
al., 2009; 2013; Galbraith-Emami &                Increasingly, it is recognised that      addressed by Better Outcomes,            et al., 2011; Galbraith-Emami &           they do not encompass the Internet.      to define items that should not be
Lobstein, 2013; WHO, 2016). For this              this is an issue of children’s rights.   Brighter Futures, Ireland’s whole-       Lobstein, 2013; Harris et al., 2013).     As use of digital media increases        advertised to children. In general,
reason, the WHO has repeatedly                    The United Nations Convention on         of-government national policy            There are further factors limiting the    among children and young people          voluntary schemes are weaker
called for reductions in children’s               the Rights of the Child (UN, 1990)       framework for children and young         effectiveness of current regulation.      in Ireland, this is becoming more of     and less well implemented and
exposure to food marketing for                    enshrines children’s rights to the       people 2014-2020 (Department of          Brands that sell primarily unhealthy      a concern. Not only do digital media     monitored than statutory regulation
unhealthy foods, most recently                    highest attainable standard of           Children and Youth Affairs, 2014).       foods can evade the ban by                provide new and engaging ways for        (Galbraith-Emami & Lobstein, 2013).
in the Report of a Commission                     health, protection from harm, and                                                 advertising with healthier items (e.g.,   brands to seek to engage children
on Ending Childhood Obesity,                      requires States to recognise the                                                  McDonald’s advertising Happy Meals        and young people, but these new

Who's Feeding the Kids Online? | Digital Food Marketing and Children in Ireland                                                                                                                                                          Irish Heart Foundation
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1.3 Digital media, children and marketing                                                                                            1.4 Understanding the effects of digital marketing and children’s ability to resist it

The media landscape has been                                                               Geolocation in smartphones also           A long-held assumption is that the         with it (Lawlor, 2009), suggesting         ‘breaks’ or identification of ads or
changed profoundly by digitisation,                                                        allows marketers to identify exactly      ability to resist advertising effects is   that they are not motivated to resist      branded content (Ali et al., 2009).
as have marketing activities                                                               where a child or young person is.         governed by conscious awareness            its effects. In social media, studies      Second, resistance may be harder
(Mulhern, 2009), and marketers                                                                                                       and understanding about ads. Most          of teens in the US and UK indicate         to activate for digital marketing
                                                                                           This host of tracking activities gives
report that digital marketing has                                                                                                    research on children and advertising       that about half to two-thirds like         such as promotional ‘advergames’
                                                                                           marketers the powerful ability to
a powerful capacity to amplify                                                                                                       has addressed the question of the          advertising and engage with it             (brand-created interactive games
                                                                                           specify what children and young
advertising effects. In France and                                                                                                   age at which children can recognise        (Logicalis, 2016; Nielsen, 2009).          incorporating branded visuals).
                                                                                           people look at online, who they
the US, market research reports                                                                                                      ads, and when they can understand          Furthermore, the impact of ads on          These are exciting and immersive,
                                                                                           are connected to, and even where
that direct return on investment                                                                                                     that advertisers wish to persuade          children’s emotions is frequently          so even when children understand
                                                                                           they are. This certainly raises
for online Coca-Cola and Cadbury                                                                                                     people to buy things. Discussions          not addressed. Psychological and           that they intend to persuade,
                                                                                           privacy concerns. However, a less
campaigns was about 4 times                                                                                                          about advertising typically                neuroscientific evidence indicates         playing them establishes positive
                                                                                           frequently discussed matter of
greater than for TV: Kantar                                                                                                          draw on this body of research to           that emotional ads are processed           brand associations (Rozendaal
                                                                                           concern is that marketers use this
calculated that for a Coca-Cola                                                                                                      conclude that once children can            with little conscious awareness and        et al., 2011). Third, considerable
                                                                                           information to target individuals,
campaign in France, Facebook                                                                                                         recognise ads, they will be able           result in ‘implicit persuasion’ (Nairn     HFSS food marketing is delivered
                                                                                           including children, more perfectly.
accounted for 2% of marketing                                                                                                        to resist them (Harris et al., 2009),      & Fine, 2008), and an audit of nearly      in the exciting, peer-saturated
                                                                                           The US Children’s Online Privacy
cost but 27% of incremental sales                                                                                                    and developmental research has             900 ad campaigns found emotional           environment of social media such
                                                                                           Protection Act (COPPA), which
(Peterson, 2014). In addition to                                                                                                     generally concluded that by the            ads (with little or no rational content)   as Instagram and Facebook, where
                                                                                           requires ‘verifiable parental consent’
direct returns on investment,                                                                                                        age of 12, children have adult-level       were most effective (Binet & Field,        children in Ireland have accounts
                                                                                           before collecting information from
online marketing creates further,                                                                                                    recognition of advertising and can         2009). Therefore, when ads focus on        from the age of about 9 years on
                                                                                           children under-13 years (coppa.org),
synergystic effects. Facebook                                                                                                        therefore resist it.                       emotions rather than information as        and where participation increases
                                                                                           discourages OBA directed at under-
reports that its ads increase target                                                                                                                                            their route to persuasion, questions       steeply from 13 years (O’Neill & Dinh,
                                                                                           13s, as does Ireland’s ASAI Code (ASAI,   And yet there are problems with
audience reach, ad memorability,                  dependence or overdependence on                                                                                               of when children can recognise an          2015).
                                                                                           2015). However, the 2015 Global           this conclusion. Even if marketing
brand linkage and likeability,                    smartphones (O’Neill & Dinh, 2015).                                                                                           ad and resist it do not apply.
                                                                                           Privacy Enforcement Network Sweep         is recognised, and understood,                                                        Even though social media
compared to television alone
                                                  One of the most pronounced               of apps and sites targeting children,     in order to resist it one must also        In this context, digital marketing         participation is intended to be
(Facebook, 2015), and Facebook
                                                  changes in marketing in the new          or popular with them, found that          activate resistance and have the           adds a number of challenges. First,        limited to those aged 13 years
ads across 14 campaigns generated
                                                  digital landscape is the shift from      two-thirds of sites and apps (67%)        motivation to do so (Rozendaal et          children find digital marketing            and up, when children typically
nearly triple the ad recall compared
                                                  broadcast to targeted advertising        across the world collect identifying      al., 2011). Yet from early childhood,      harder to identify than television         recognise and understand the
to control groups (Gibs & Bruich,
                                                  that is crafted for individual users’    information from children (Data           children often describe enjoying           advertising, as it is typically            purpose of advertising, the presence
2010). Econometric analysis of fast-
                                                  demographics and their online            Protection Commissioner, 2015), and       advertising and wishing to engage          presented without clear ad                 of HFSS marketing in social media is
moving consumer goods brand
                                                  behaviours (Online Behavioural           apps / websites tested for Ireland                                                                                              a concern. Research demonstrates
marketing (including food and
                                                  Advertising, or OBA). To deliver OBA,    collected technical data such as                                                                                                that teens are more susceptible
drinks) in Europe found that online
                                                  technical and personal information       cookies (61%), UID (unique identifier                                                                                           to marketing than adults, due to
marketing magnifies returns on
                                                  about Internet users is collected        of a computer; 50%), IP address (28%),                                                                                          factors such as reduced inhibition
other media investment, e.g., a 70%
                                                  from websites, social media and          and Geolocation (28%). In addition,                                                                                             and gratification delay; greater
increase for TV and 71% for cinema
                                                  apps, using site or competition          once children are 13 years old, or                                                                                              responsiveness to peer influence;
(Microsoft, 2013).
                                                  registration forms and many digital      earlier if they signed up for a social                                                                                          and the developmental need to
Digital HFSS marketing is a concern               identifiers and trackers. ‘Cookies’      network with a false date of birth,                                                                                             establish their own identity (Harris
as rates of children’s Internet use               (a small piece of data sent from a       marketers, brands, digital platforms                                                                                            et al., 2009; Harris et al., 2014;
are rising in Ireland. Three-quarters             website and stored in the user’s         may target them freely.                                                                                                         Pechmann et al., 2005). A substantial
of 9-16 year olds access the Internet             web browser), which are quite easily                                                                                                                                     part of teens’ ‘identity work’ – a key
                                                                                           Marketers take advantage of
daily; nearly 20% go online for                   deleted, have been augmented by                                                                                                                                          task of adolescent development
                                                                                           these rich digital data to create
more than 3 hours daily at the                    a host of more persistent tracking                                                                                                                                       – now takes place in social media
                                                                                           ‘unprecedented intimacies’ between
weekends and 40% are online for                   methods such as flash and zombie                                                                                                                                         (boyd, 2014b), including through
                                                                                           them and children (Montgomery
more than an hour daily during the                cookies and device fingerprinting;                                                                                                                                       consumer practices, representation
                                                                                           et al., 2012). Furthermore, such
week (O’Neill & Dinh, 2015). With a               these can follow users’ journeys                                                                                                                                         and transfer of symbolic meaning
                                                                                           targeting methods are shutting out
smartphone, children in Ireland feel              and activities online in detail, even                                                                                                                                    from brands, which function as
                                                                                           researchers and policy makers who
more connected to their friends;                  following them from one device to                                                                                                                                        psychological symbols of personal
                                                                                           wish to measure digital marketing to
three-quarters feel they must always              another, mapping every device they                                                                                                                                       attributes and social goals (Levy,
                                                                                           children and its effects. We return to
be available for contact; nearly half             use, every web location they explore                                                                                                                                     1969, in Leiss et al, 2013; McCreanor
                                                                                           this below in section 1.5, before first
often feel a strong need to check                 and what they do there, and all the                                                                                                                                      et al., 2005). In relation to food in
                                                                                           considering children’s susceptibility
their phone; and four in ten display              links in their social networks (Office                                                                                                                                   particular, neuroimaging research
                                                                                           to digital marketing.
two or more such indicators of                    of the Privacy Commissioner, 2015).                                                                                                                                      of food advertising has found

Who's Feeding the Kids Online? | Digital Food Marketing and Children in Ireland                                                                                                                                                             Irish Heart Foundation
12                                                                                                                                                                                                                                                          13

teens to be particularly responsive               In Ireland, adolescents are              In sum, therefore, although teens         ‘Competitive intelligence analysis’       Therefore, as researchers do not          generated by the role that digital
(Gearhardt et al., 2014) and research             influenced in HFSS choices by peers;     have adult-level understanding of the     of digital marketing (analyses of         have access to the carefully-guarded      platforms now play in public life
across Europe from Ireland to Cyprus              enjoy eating such foods with friends;    purpose of advertising, this does not     data carried out by analysts external     marketing analytics on children           and the communications landscape
has found that teens use unhealthy                use their increased autonomy             protect them from emotion-based           to a company), which can identify         available to social media platforms       (Pasquale, 2015; Sandvig et al., 2014;
food as a peer activity and a                     within restricted budgets to buy         marketing. Many are particularly          some demographics of users’ online        and food brands, it is impossible         Tufekci, 2015).
feature of their generational, ‘teen’             HFSS foods; and strongly prefer          susceptible to food marketing – yet       behaviour, is less accurate in small      to specify how much digital
                                                                                                                                                                                                                         While researchers work on
identity (Fitzgerald et al., 2010, 2013;          HFSS foods despite understanding         the teen years are largely neglected      countries such as Ireland due to          advertising children and young
                                                                                                                                                                                                                         developing methods and gaining
Ionnanou, 2009; Stead et al., 2011;               healthy eating principles (Fitzgerald    where food marketing policy and           small samples (Kaushik, 2015). And        people actually see, particularly in
                                                                                                                                                                                                                         access to data, it remains critical
Trew et al., 2005).                               et al., 2010).                           research are concerned.                   researchers who analyse large-scale       smaller countries such as Ireland.
                                                                                                                                                                                                                         to understand the HFSS digital
                                                                                                                                     social media datasets (‘Big Data’) told   This is a research area that is certain
                                                                                                                                                                                                                         marketing techniques that children
                                                                                                                                     us they could not reliably segment        to develop rapidly in the coming
1.5 Identifying digital food marketing seen by children: An imbalance of access and power                                                                                                                                and young people are exposed to, as
                                                                                                                                     users by age, a crucial requirement       months and years. It is also a topic
                                                                                                                                                                                                                         digital marketing, rather than simply
Despite the many factors described                see is targeted or personalised to       The atomisation of children’s media       for those interested in children’s HFSS   for ethical discussion, as ever-greater
                                                                                                                                                                                                                         replacing traditional advertising,
above indicating that children                    varying degrees. The platforms,          practices presents challenges to          marketing exposure online.                imbalances of power are being
                                                                                                                                                                                                                         amplifies its effects.
and young people are likely to                    sites and channels they view online      researchers seeking to understand
be susceptible to digital food                    are fragmented, by age, gender           digital food advertising to children,
marketing, identifying their exposure             and country, and over time. As an        but the greatest challenge of all is
                                                                                                                                     1.6 Who’s responsible? An issue of choice, or of children’s rights?
to marketing of HFSS food and drink               example, UK research with over 400       presented by online behavioural
is extremely challenging (Cairns,                 children aged 7 to 12 years (drawn       advertising (OBA).
2013). One might imagine, in a                    from a panel of 25,000+ children run
                                                                                           As noted above, in the process of
relentlessly data-driven age, that                by digital marketers SuperAwesome;
                                                                                           delivering OBA, brands, media and            6’6”
information on children’s and young               December 2013) reported YouTube
                                                                                                                                        6’0”
                                                                                                                                                            ?                      ?                         ?                     ?
                                                                                           marketing platforms gather vast
people’s media practices, and on                  as the most popular site among boys
                                                                                           amounts of information on young
the ‘reach’ of digital marketing to               and girls aged 7-12 – but YouTube
                                                                                           people’s marketing exposure and              5’6”
children, would be easy to come                   houses millions of channels, so
by. Yet this is not the case. While               this doesn’t clarify which channels
                                                                                           engagement, and conduct extensive            5’0”
                                                                                           and sophisticated analyses of their
researching this report, we made                  children are viewing. Gender
                                                                                           behaviours. However, researchers             4’6”
contact with digital marketers,                   differences were also evident with
digital marketing researchers, and                girls favouring Facebook, Movie
                                                                                           cannot simply ‘go online’ to identify
                                                                                           the advertising children see, as
                                                                                                                                        4’0”
digital data and Big Data specialists             Star Planet and CBBC whereas
                                                                                           researchers have different platform,
in Ireland; with UK digital marketers             boys preferred Friv, Minecraft and
                                                                                           browser and device histories to
who specalise in marketing to                     Facebook.
                                                                                           children and young people and are
children; and with international
                                                  Furthermore, children’s and young        therefore unlikely to be delivered
researchers monitoring food
                                                  people’s digital media preferences       the same ads. Researchers also
marketing to children and young
                                                  may change rapidly, although             cannot access proprietary industry
people. No-one could direct us                                                                                                       Finally, it is important to highlight     food marketing is an integral part        As the use of the language of
                                                  media storms about the ‘death’ of        data because it is rarely made
to good quality information on                                                                                                       that, when food marketing                 (Swinburn et al., 2011). Obesogenic       ‘choice’ places all the responsibility
                                                  certain online locations should be       available to outsiders. On the rare
the extent and nature of digital                                                                                                     to children is being debated,             environments prompt frequent              on individuals, and none on
                                                  treated with caution, as these are       occasions that limited analyses are
marketing to children and young                                                                                                      discussions are usually framed            consumption of unhealthy foods,           food companies, marketers and
                                                  often based on anecdotal reports of      available, the cost is prohibitive
people in Ireland that was available                                                                                                 around twin rhetorics of ‘choice’         interfering with individuals’ ability     governments, understanding
                                                  single individuals or small groups, or   (e.g., we were quoted over €60,000
to individuals outside industry at a                                                                                                 and ‘parental responsibility’. Food       to act in their own long-term             parents’ views of digital food
                                                  misinterpretations of evidence (boyd,    for some rudimentary information).
reasonable cost.                                                                                                                     companies state their belief that         interest. Food companies promote          marketing is important. Do they
                                                  2015; Cellan-Jones, 2013; Magid, 2015;   Some companies (such as comScore,
On TV, advertising is broadcast                   see also Mascheroni & Ólafsson,          Alexa and others) do sell some data       from the teens onward, individuals        availability and affordability of         believe the issue of food, eating
in single blocks to large numbers                 2014, p.35 note 9). Finally, it should   on children’s digital activity and        can make rational choices about           unhealthy foods (Greenfield, 2011;        and food marketing is primarily a
of people. As long as one knows                   be borne in mind that not all online     marketing exposure, but not for           their snacking and eating – see           Swinburn et al., 2011), and spend         matter of choice for themselves
which channels and times have high                locations popular with children and      under-15s in Ireland, and drawing         for example Mars’ marketing code          vast budgets on building emotional        and for young people? Or do they
child viewership, it is relatively easy           young people feature advertising,        inferences from other countries           (Mars [no date]) – and parents are        associations with them – one              agree with the WHO (2016) and the
to measure children’s advertising                 although it can be expected that         is problematic, as inter-country          assigned primary reponsibility for        estimate found that food companies’       United Nations Special Rapporteur
exposure. Online, however, media                  wherever it is absent, sites will        differences in children’s digital media   their children’s eating (Handsley et      spend on promoting unhealthy              (UN, 2014) that society has a moral
and children’s uses of it are highly              eventually seek to ‘monetise’ their      use can be pronounced (O’Neill &          al., 2014). However, such positions       foods is approximately 500 times          responsibility to protect children’s
fragmented. Children see marketing                offerings. For example, Instagram        Dinh, 2015). In fact, seeking data on     ignore the strong evidence for the        the amount that the WHO spends on         right to health and restrict children’s
in some online settings, but not                  was ad-free until advertising began      children’s digital practices in a small   impact of present-day ‘obesogenic’        promoting healthier practices (Lang       and young people’s exposure to
others, and the marketing they                    late in 2015 (Delzio, 2015).             country is a particular challenge.        food environments, of which               & Millstone, 2002).                       food marketing?

Who's Feeding the Kids Online? | Digital Food Marketing and Children in Ireland                                                                                                                                                            Irish Heart Foundation
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1.7 Aims of this study
In conclusion, basic knowledge                    the digital food and drink marketing     and young people in Ireland, and
is missing about the digital food                 appealing to, or directed at, children   is a location where advertisers are
marketing that children and teens                 and young people in Ireland. It          also very active. Finally, to indicate
are exposed to in Ireland, and about              studied (1) websites of top Ireland      what information families need, and
parents’ knowledge and attitudes on               food and drink retail brands – as        whether there is a public appetite for
this topic. Although data available to            reports from other countries indicate    regulation of digital food marketing
non-industry researchers on digital               these have much content directed at      to children, the report also explored
marketing are currently extremely                 young children – and (2) Facebook        (3) parent awareness and views in
limited, this study aimed to make                 brand Pages – as Facebook is a single    Ireland of digital food marketing.
essential first steps in identifying              platform, most popular with children

                                                                                                                                    2. On the homepage:
                                                                                                                                    Websites of top food and drink retail brands

Who's Feeding the Kids Online? | Digital Food Marketing and Children in Ireland                                                                                                    Irish Heart Foundation
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2. On the homepage: Websites of top food and                                                                                          Examples of websites with child-directed content – from 73 websites of the 100 top retail
                                                                                                                                      brands in Ireland
drink retail brands                                                                                                                   Website                               Tab           Child-directed content

                                                                                                                                      www.pom-bear.co.uk/home¹              Family Fun    ■■   Homepage (see image) had bright colours, cartoon
      In Australia, the US, Canada, and the UK, studies report that 3 to 8 out of 10 websites of food and soft                        (KP snacks)                                              images, large bold graphics
      drink brands, primarily for HFSS products, have features designed for children, such as children’s                                                                                  ■■   Family fun tab had craft ideas, e.g., create PomBear-
                                                                                                                                                                                               decorated Christmas lanterns, cups
      areas, advergames, brand spokescharacters, videos, ‘webisodes’, branded education and interactive                                                                                   ■■   A 10 question nutrition quiz implied that eating Pombear
      features, all designed to engage children in lengthy brand-related exposure and build positive                                                                                           snacks (potatoes) and ketchup (tomatoes) is good for
                                                                                                                                                                                               health
      associations with the products and brands (Henry & Story, 2009; Cheyne et al., 2013; Kelly et al.,                                                                                  ■■   When Googling ‘PomBear games’ we were linked to www.
      2008; Potvin Kent et al., 2013). As far as we know, there has never been a systematic examination of                                                                                     pom-bear.co.uk/games/world-builder/login.html

      websites for food and drink products in Ireland, to identify techniques appealing to children.

As data are not available on the food                                                                                                 www.taytocrisps.ie²                   Fun Stuff &   Tayto Crisps homepage (see image): Bright colours, story-book
                                                                                                                                      Led to www.taytopark.ie               Colouring     style cartoon-like illustrations and featured Mr Tayto.
and drink brands that are of greatest
                                                                                                                                                                            Pages         ■■   Fun Stuff tab led to a ‘Mastermind’ quiz about Tayto.
appeal to children in Ireland, we
                                                                                                                                                                                          ■■   Colouring Pages: Pdfs (Mr Tayto/ bag of Tayto crisps)
identified 83 of Ireland’s top food
                                                                                                                                                                                          ■■   Tayto Park linked to www.taytopark.ie
and drink retail brands from a listing
                                                                                                                                                                                          ■■   Children, teens on theme park attractions.
of Ireland’s 100 top retail grocery
                                                                                                                                                                                          ■■   Zoo: introductions to animal galleries. dedicated animal
brands (Checkout, 2014; based on                                                                                                                                                               pages
Nielsen ranking of over 6,500 brands                                                                                                                                                      ■■   Early October: Hallowe’en, Santa visits featured
in over 200 product categories of
‘fast moving consumer goods’).
Google searches were conducted to                                                                                                     www.avonmore.ie³                      Bó Corner     ■■   Parent-directed site with Bó Corner tab (Bó page – see
locate brand sites with .ie (Ireland)                                                                                                                                                          image)
domain addresses. If none could                                                                                                                                                           ■■   Bó Chase game (only the page itself was branded; see
                                                                                                                                                                                               image). A cow herds unbranded glasses of milk onto a milk
be located, the .co.uk (UK) site was                                                                                                                                                           float; Heard [sic] the glasses of milk onto the Avonmore
examined; where neither was found,                                                                                                                                                             milk float as fast as you can without spilling any. Careful
.com (international, usually US sites)                                                                                                                                                         now!).

websites were explored, some of                                                                                                                                                           ■■   Pdfs of colouring sheets.

which redirected to Irish sites or
content.
                                                                                                                                      www.john-west.ie⁴                     Trawler       More parent-directed:
2.1 Kids’ and fun areas on                                                                                                                                                  Fun           ■■   Entertainment for Tiddlers and Old Sea Dogs
food and drink websites                                                                                                                                                                   ■■   Downloads of colouring sheets
                                                                                                                                                                                          ■■   Link to YouTube video
Websites were found for 82 of the
83 brands (73 individual sites; see
Appendix). Some, e.g., Cadbury,
                                                  that no site had a section named kids     were parent-oriented (Flora, John
Denny, Avonmore, host multiple
                                                  or children, and overtly designated       West, and Avonmore) and three were
products; other brands have more
                                                  children’s areas were almost entirely     somewhat child-oriented (Miwadi,
than one site, e.g., Tayto crisps has a
                                                  absent. Of the 73 sites, 8 had a tab or   Tayto crisps, and the Tayto Park site).   Not Shown:
tab that leads to the Tayto Park site.
                                                  image on the homepage named Fun,          Finally, the Pombear site (a KP Snacks
A full ‘sweep’ of the 73 websites was                                                                                                 www.miwadi.ie                         Fun           A ‘Fun’ tab led to a set of options:
                                                  a child-oriented Corner, or content       brand) was the only site identified
conducted between 28 September                                                                                                                                                            ■■   A simple game, similar to the Avonmore game (only the
                                                  for children to engage with (the          that was strongly child-oriented with
and 10 October 2015, to identify                                                                                                                                                               page itself was branded, not the game): Catch fruit as it
                                                  Pepsico.ie site was then excluded as      substantial child-related content                                                                  falls in a truck
designated children’s areas and
                                                  it was an adult-directed, corporate       and bright colours and the PomBear                                                            ■■   Screensaver (bottle of Miwadi, glasses slowly filling up)
content appealing to children and
                                                  site, and the Fun tab stated that Life    brand character throughout. These                                                                  may be appealing to children
young people.
                                                  can’t be all about work). Seven sites     are shown in the table.                                                                       ■■   Downloadable wallpaper (oranges growing on a tree) less so
In contrast to reports from other                 (10%) had some (often minimal)
countries, it was encouraging to find             child/fun-oriented content. Three                                                   www.flora.com                         Family Fun    ■■   For parents to do with children
                                                                                                                                                                                          ■■   Recipes, baking suggestions, and other activities

Who's Feeding the Kids Online? | Digital Food Marketing and Children in Ireland                                                                                                                                                        Irish Heart Foundation
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However, it should be noted that                  should be included in further                      for long periods. Its disclaimer on           2.3 Appealing to families
our focus on .ie sites for top retail             analyses of this topic. For example,               the home page (‘Hey kids, this is
brands in Ireland meant that other                the McDonald’s Happy Meal site                     advertising’) on the very top left is         Finally, it was notable in our analyses       were currently targeting parents of              12 and over as this is the age at which
websites that may seek to engage                  (www.happymeal.com) is extremely                   in exceptionally small type, and is           that websites for top food and drink          young children instead. This raises              we believe that people can make
young children in Ireland were not                child-oriented and engaging, with                  visually swamped by the engaging              retail items in Ireland frequently            the interesting possibility that a               informed choices about sensible snack
examined in this study. Sites from                loud music on launch and many                      fonts and visuals of the other site           appealed to parents, rather than              climate of regulation can change                 consumption’.
other countries, sites for fast food              games, videos, sounds, music,                      content.                                      children, through ‘family’ games              social norms about marketing to
                                                                                                                                                                                                                                                  This – along with the content of
restaurants, and sites for products               ebooks and other activities that                                                                 and activities; competitions; or free         children. However it is also possible
                                                                                                                                                                                                                                                  the food brand websites viewed –
particularly designed for children                could keep a young child occupied                                                                gifts, e.g. Kelloggs offered bowls            that marketers have simply made
                                                                                                                                                                                                                                                  raised the issue of food marketing
                                                                                                                                                   for children and adults and seeds             a decision – as they did in the
                                                                                                                                                                                                                                                  for unhealthy items that is aimed
                                                                                                                                                   and growing kits, all branded with            UK when television restrictions
  Example of child-oriented fast food restaurant site with engaging and immersive appeal for                                                                                                                                                      at teens. Companies such as Mars
                                                                                                                                                   their proprietary characters. Sites           came into force around children’s
  young children                                                                                                                                                                                                                                  and Coca-Cola state their belief that
                                                                                                                                                   also offered nutrition, eating and            programming – to direct their efforts
                                                                                                                                                                                                                                                  it is appropriate to market snacks
  Website                                                  Tab             Child-directed content                                                  cooking suggestions: e.g., Hellmans’          elsewhere.
                                                                                                                                                                                                                                                  and other foods to young people
                                                                                                                                                   offered tips to get children eating
                                                                                                                                                                                                 Notably, the sweep identified three              from 12 or 13 years as they can make
  www.happymeal.com⁵                                       Entire site     The site is aimed at young children. Content is extremely               vegetables: They’ll soon be convinced
                                                           is child-       engaging.
                                                                                                                                                                                                 websites (Mars sites Galaxy and                  informed choices about sensible
                                                                                                                                                   that vegetables really are delicious
                                                           oriented        It launches with very loud, catchy music and features bright                                                          M&Ms, and Kinder) that had ‘age                  snack consumption (Coca-Cola [no
                                                                                                                                                   when mixed with their favourite
                                                                           colours and animation                                                                                                 gates’ where a date of birth needs               date]; Mars [no date]). Yet in Ireland,
                                                                                                                                                   mayonnaise or ketchup. Through
                                                                           Facilitates an all-round marketing experience. Store toy                                                              to be entered to gain access to the              broadcast regulations do not permit
                                                                           giveaways unlock a video game and many engaging and                     such approaches, it appears
                                                                                                                                                                                                 site. This was in line with stated               advertising of HFSS products to
                                                                           entertaining games.                                                     brands are seeking to encourage
                                                                                                                                                                                                 company policies not to market                   under-18s. As noted in Chapter 1,
                                                                           Tabs:                                                                   parents to involve brands in their
                                                                                                                                                                                                 directly to children 12 and under.               in the teen years, young people
                                                                           ■ Toys ■ Create ■ Games                                                 children’s lives. This chimed with
                                                                           ■ Videos ■ Happy ■ eBooks
                                                                                                                                                                                                 Maltesers, also a Mars brand, had                may be particularly vulnerable to
                                                                                                                                                   informal discussions we held with
                                                                           A tiny ‘Hey, kids this is advertising’ disclaimer is at the top left.                                                 a website home page with only                    developing unhealthy eating habits,
                                                                                                                                                   digital marketers in Ireland. They
                                                                           A healthy eating message to ‘balance your fun’ with apple                                                             an image of a Maltesers bag, an                  and to many marketing approaches
                                                                                                                                                   said that, as marketing unhealthy
                                                                           slices is at the bottom of the page.                                                                                  invitation to visit us on Facebook               employed online. Therefore, the 73
                                                                                                                                                   foods directly to young children
                                                                                                                                                                                                 (where the official minimum age is               websites were examined again to
                                                                                                                                                   was now considered unethical in
                                                                                                                                                                                                 13 years) and explained that ‘we only            identify features that may appeal to
2.2 Advergames and apps                                                                                                                            a climate of statutory regulation
                                                                                                                                                                                                 promote our products to people aged              teens.
                                                                                                                                                   in broadcast media, marketers
The 73 food and drink retail websites             free (Glayzer, 2015). An example is a              their functionality, such as their
were examined for any advergames,                 racing car app by Kinder Bueno on                  accessibility from an Irish IP address
which were also found to be rare.                 play.google.com, a simple game that                as well as the specifics of personal
                                                                                                                                                     Examples of age ‘gates’ on HFSS food websites
Two sites, Avonmore and Miwadi,                   would appeal to young children. A                  information collected from the
each hosted an easily accessible                  constant stream of Kinder Bueno6                   user. As noted in Chapter 1, apps
child-oriented game, that involved                logos features during game play.                   frequently breach US and Irish
collecting milk or fruit, was very                Other informational and play-based                 guidelines, raising concerns about
simple and was aimed at young                     apps feature HFSS brands, such as                  further tracking and targeting
children. However, as these did                   the Haribo weather app featuring                   of children with marketing (Data
not have branded visuals or offer                 the brand’s bear. Interestingly, some              Protection Commissioner, 2015).
an immersive experience, they do                  apps restricted their geographic
not fit the generally understood                  availability, such as the McDonald’s
category of ‘advergames’. When                    Minions movie tie-in Min-ball app,
searching for branded games                       ‘appropriate for ages 4+’, which was                                                             M&Ms age ‘gate’ ⁷                                                   Kinder age ‘gate’ ⁸
through Google, one advergame                     not available in the Irish iTunes store
                                                                                                                                                                                                                       Our promise. At Mars we take our responsibility for marketing our brands
was found. A PomBear games site                   (the site doesn’t allow linking to the
                                                                                                                                                                                                                       appropriately very seriously. We have a Marketing Code that governs all
login page appeared with links to                 US store). Such practices indicate                                                                                                                                   our promotional activity and states that we only promote our products to
games directed at young children;                 that despite the global reach of the                                                                                                                                 people aged 12 and over as this is the age at which we believe that people
this had not appeared when                        internet, it is possible for geographic                                                                                                                              can make informed choices about sensible snack consumption. We apply
navigating the website itself.                    limits to be placed on marketing to                                                                                                                                  our Marketing Code to all our advertising and communications and are
                                                                                                                                                                                                                       committed to providing you and your family with suitable and transparent
                                                  children.
It should be noted that advergames                                                                                                                                                                                     information about our products. For more information about how we
have not disappeared from the                     A full sweep of HFSS brand apps                                                                                                                                      promote our products responsibly, please follow the link to the Mars
marketing landscape. Instead, they                aimed at children and available                                                                                                                                      Marketing Code.

appear to have migrated to app                    from online app stores is required.
                                                                                                                                                   Maltesers home page (prominent link to Facebook) ⁹                  Maltesers Marketing Code on website (Mars [no date])
and game stores to download for                   This should assess the apps and

Who's Feeding the Kids Online? | Digital Food Marketing and Children in Ireland                                                                                                                                                                                          Irish Heart Foundation
20                                                                                                                                                                                                                                                                    21

2.4 Food and drink website features appealing to teens                                                                               Continued.
Websites were excluded from                       Sites were also excluded if they          Avonmore, John West, PomBear or
                                                                                                                                      Lucozade
consideration for teen-appealing                  had child-related content that was        Miwadi above).
                                                                                                                                     www.lucozadeenergy.ie
content if they had                               directed primarily at parents or
                                                                                            The remaining sites were evaluated       www.lucozadesport.ie/rugby-instant-win13
                                                  teachers, e.g., lunchbox tips (Denny),
■■ little or no consumer-oriented                                                           for appeal to teens by three raters:     Searching for Lucozade Sport directly opened
                                                  tips for getting children to eat                                                   the Win Official Rugby Shirts Every 80 Minutes
   content; or                                                                              two adults (a developmental
                                                  more fruit or vegetables (Hellmans,                                                competition. This is 18+ but that is only made
                                                                                            psychologist, and a marketing
■■ consumer-oriented content                      Tropicana), baking (Dr. Oetker, Flora),                                            evident on the second, competition entry page.
                                                                                            professional who also manages
   limited to product images                      school-based lunch club (Brennans
                                                                                            marketing compliance) and a teen.
   and basic product/nutritional                  bread), food pyramid or nutrition-
                                                                                            To be considered to have appeal
   information; or                                related tests or quizzes (Irish Pride),
                                                                                            to teens, a site needed to have (i) a
■■ content directed at general                    or free cereal bowls for younger                                                    KitKat
                                                                                            homepage that was visually strong
   adult audiences (e.g., Batchelors,             children and adults (Kelloggs).
                                                                                            and youth-appealing, and (ii) teen-      www.KitKat.co.uk/content14
   Donegal Catch Green Isle 2                     Finally, sites were excluded if the
                                                                                            appealing content. Any differences       Despite the office scene on the home page, the
   Sisters Group, Charleville, Brady              main focus was on family-oriented                                                  overall air of humour and relaxed leisure gives it
                                                                                            were resolved by discussion, with
                                                  fun or content was directed                                                        teen appeal. A main tab (not a small tile icon) links
   Family Ham, KP Snacks, Pepsico,                                                          the casting vote given to the teen.      to YouTube, launching a video of a ‘ninja’ teddy
   Magnum, and Hunky Dorys).                      primarily at younger children (e.g.,
                                                                                                                                     with a KitKat, by animator Patrick Boivin, and also
                                                                                                                                     featuring vlogger Marcus Butler with the ‘Google
                                                                                                                                     my break’ feature. Both are likely to have strong
                                                                                                                                     appeal for teens.
  Examples of websites of 73 top retail food brands in Ireland assessed as having appeal to teens
 Websites featuring HFSS items, not recommended for marketing to children and young people under WHO                                  Ben & Jerry
 Nutrient Profiling Guidelines (WHO, 2015)                                                                                           www.benjerry.ie15
                                                                                                                                     Both the product and the environmental cause are
  Coca-Cola                                                                                                                          likely to have strong appeal to teens, amplified by
                                                                                                                                     the strong graphic identity of the home page and
  www.Coca-Cola.ie                                                                                                                   product.
  www.happiness.Coca-Cola.com/ie/en/hom10
  The Coca-Cola happiness site is strongly teen-
  oriented in its visuals and content throughout, with
  entertainment and activity-oriented downloads,
  competitions, creative content co-creation, sports
  and more.
                                                                                                                                      Not shown: Club Orange
                                                                                                                                     www.club.ie links to www.bestbits.ie
                                                                                                                                     The Club Orange site redirected to bestbits.ie; when clicked on, this home page opened a site with social media feeds featuring
  Pringles                                                                                                                           competitions and a model showing substantial cleavage in an orange grove.

  www.pringles.com/ie/home11
  The Pringles homepage features 3 separate                                                                                         In total, 13 websites, 18% of the               The teen-appealing content                   downloads, World Cup rugby shirts,
  promotions for karaoke kits, Xbox and movies, all
                                                                                                                                    73 food and soft drink sites,                   on websites fell into three                  UEFA Champions league tickets
  of potential appeal to teens which require unique
  product codes. The Terms and Conditions (18+) are                                                                                 were assessed as having features                broad clusters which could be                and crates of soft drinks. There was
  hard to find.                                                                                                                     appealing to teens. These are shown             characterised as evoking emotion             considerable overlap across these
                                                                                                                                    in the table on these pages, and as             through fun and excitement. These            clusters of teen-appealing features,
                                                                                                                                    the assessment of appeal to teens               were entertainment features                  with sites featuring multiple appeals,
                                                                                                                                    was a qualitative judgment, in the              that appealed to teens through               so on page 23 we present examples
                                                                                                                                    digital Appendix we show examples               music, theme parks, festivals,               together.
  Tayto
                                                                                                                                    of homepages that were considered               gaming, YouTube and other media
  www.taytocrisps.ie                                                                                                                for inclusion but agreed by raters              content; celebrities from sport and
  www.taytocrisps.ie/park12                                                                                                         to be less appealing to teens. The              entertainment featured in multiple
  The Tayto Crisps homepage is humorous, slightly
                                                                                                                                    products and brands featured on                 sites; and competitions/promotions
  surreal (with iconic Dublin landmarks in a
  countryside setting) and features Mr Tayto.                                                                                       the sites were evaluated to identify            which drew attention to brands
  It links to the Tayto Park site shown here, featuring                                                                             whether they were high in fat,                  through many different offers:
  teen-appealing theme park rides (see examples                                                                                     salt and sugar. To do so the WHO                movie downloads, karaoke kits,
  below), and at the time of the study Halloween-
  themed events.
                                                                                                                                    European Region Nutrient Profiling              Xboxes, selfie sticks, power banks,
                                                                                                                                    model (WHO, 2015) was applied.                  festival tickets, branded emoji

Who's Feeding the Kids Online? | Digital Food Marketing and Children in Ireland                                                                                                                                                                     Irish Heart Foundation
22                                                                                                                                                                                                                                                                                 23

  Examples of websites of 73 top retail food brands in Ireland assessed as having appeal to teens                                        Examples of features of websites for food and drink likely to appeal to teens
 Websites featuring non-HFSS items, cleared for marketing to children and young people according to WHO
 Guidelines (WHO, 2015).

  Volvic
  www.volvic.co.uk16
  After reflection (with doubts about whether
  teens would spend limited budgets on water) we
  retained the Volvic site in the section appealing
  to teens. This was for its music festival theme, an
  engaging count-down to the volcano ‘explosion’,
  and appealing infographics on the site about
  health benefits of water.

  Glenisk
                                                                                                                                       Entertainment: Co-creating content, downloading                          Entertainment/celebrity: Angela Scanlon (TV presenter & digital host of
  www.glenisk.com17
                                                                                                                                       Coca-Cola emojis and cycling on Coca-Cola city bikes 18                  The Voice) launched Coke’s 360 festival selfie stage 19
  Although most of the Glenisk site is adult- and
  parent-directed, the homepage has a powerful
  image featuring its IRFU sponsorship and high-
  protein, low fat yogurts. It was therefore considered
  to have appeal to sport-, fitness- and diet-oriented
  teens. As the yogurts have less than 10g sugar per
  100g, they would pass WHO guidance (2015) for
  marketing to children.

2.5 Competitions
Many competitions or promotions                   Agency of Ireland Code’s 7th Edition       query about excessive consumption.
had strong teen appeal, whether                   (ASAI, 2015), which came into force        In the Republic of Ireland (RoI), every
explicitly aimed at children/ teens               in March 2016, which requires that         entry required purchase of a 500ml
or not, and thus had the potential                promotions’ terms and conditions be        promotional pack of Coca-Cola; and
to build interest in HFSS products.               ‘prominently stated’ (Rule 5.16). The      up to 20 entries per person, per day      Sport/celebrities: Glenisk is the official yogurt of the IRFU and        Sport/celebrities: Rugby World Cup stars feature in a Lucozade
In several cases age restrictions                 teen researcher who co-reviewed            were permitted. For comparison, in        Ireland rugby stars feature 20                                           Sport competition 21

were not shown where the prize                    the sites said of the Pringles offers,     Northern Ireland no purchase was
was advertised on the website, and                ‘that’s cool, but I would never click      necessary and entry was limited
terms and conditions (for example,                on those [Terms and Conditions]’.          to one per person per day. The RoI
limiting participation to over-18s)               Somewhat clearer communication             condition could be considered to
were difficult to find.                           of age restriction was seen, for           facilitate or encourage excessive
                                                  example, in the lucozadesport.ie           consumption, against the ASAI
An example was the Pringles
                                                  Win a Rugby Shirt every 80 Minutes         Code 7th Edition (ASAI, 2015, 8.21b)
site, with strong teen appeal
                                                  competition (see images on p.24).          that, in marketing to children under
and featuring three separate
                                                  Although the 18+ entry requirement         16, communications featuring a
competitions/promotions for
                                                  was not displayed on the homepage          promotional offer linked to a food
karaoke kits, Xbox and movies (see
                                                  where the competition was                  product of interest to children
image on p.20). Locating the terms
                                                  advertised, the first click to the entry   should ‘avoid … encouraging the
and conditions required clicking
                                                  screen showed the need to enter            purchase of an excessive quantity for
onto the relevant promotion or
                                                  date of birth prominently.                 irresponsible consumption’.
competition page, scrolling past
                                                                                                                                       Entertainment: Red Bull site with features on gaming and music news 22
product entry codes and other                     Coca-Cola’s WIN Enjoy your favourite
appealing content, and identifying a              Coke for a chance to win a Coke Selfie
link in very small type at the bottom             Stick promotion (summer 2015) was
of the webpage (see images on                     open to those aged 13 and over
p.24). In our view this would breach              (with parental permission if under
the new Advertising Standards                     16). Its terms and conditions raise a

Who's Feeding the Kids Online? | Digital Food Marketing and Children in Ireland                                                                                                                                                                                Irish Heart Foundation
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