We are acutely aware that there could be a snap general election or decision to have a second referendum over the next few months.
The Government’s response to the DCMS Disinformation & “Fake News” inquiry has positively announced some legislation for political ad reform. However, as the committee discussed it will not come into force until 2020 or 2021. We would therefore like to put forward a proposal on how we can accelerate the reform of political advertising and restore the trust of the electorate in any upcoming political process by requesting that political advertisers should adopt a campaign pledge for responsible election campaigning.
We are putting the pledge forward as a starting point, and encourage feedback and further input. It is based on our 4-point plan. We put our plan together as points we felt would be hard to argue against, so easiest to gain consensus around while also having the biggest impact. There are obviously various other areas that should be carefully considered as required by law (for example, spending limits and controls that have been looked at by the Electoral Commission). Also ensuring your campaign is compliant with GDPR.
We are a politically neutral initiative and would like all the main parties to sign up to the pledge. We are in conversations with several parties and are delighted that Change UK – The Independent Group have already adopted it.
We propose the pledge adopted should be simply:
We the <name of party> will practice responsible election campaigning and pledge to:
1. Always include in our digital advertising information so that voters can identify the ad as ours.
2. Publish our digital paid-for advertising content on a publicly available webpage.
3. Share the substantiation of any objective factual claims used in ads on a publicly available webpage or on the ad itself.
4. Revise or suspend any claims that that our nominated independent fact checking services find to be misleading.
- Always include in our digital advertising information so that voters can identify the ad as ours.
Imprints / watermarks on all digital ads should be as per the Electoral Commission’s suggestion that “all electronic campaigning should have easily-accessible digital imprint requirements, including information on the publishing organisation and who is legally responsible for the spending”.
- Publish our paid-for digital advertising content on a publicly available webpage.*
- who is paying for the ads
- which organisations are sponsoring the ads
- the audience targeted by the ads.
The above criteria are recommended by the DCMS Disinformation & “Fake News” report and are to ensure transparency of campaign messaging and to avoid “dark ads”. We believe that this would be a temporary measure until the “publicly accessible searchable repository [for political ads] run independently of political parties and the ad industry”, recommended in the report, is available.*
- Share the substantiation of any objective factual claims used in ads on a publicly available webpage or on the ad itself.
Substantiate objective factual claims. This substantiation could be included in the ad itself or published independently and publicly together with any digital ads being used in the campaign.
- Revise or suspend any claims that a nominated independent fact checking service find to be misleading.
All non-political ads which appear on TV or VOD and make factual claims are already, in ad terminology, “pre -cleared” by an organisation called Clearcast. This is an advisory service for advertisers which they can choose to ignore. However, the Advertising Standards Authority (ASA) rules on complaints which are submitted to it, and will take into account Clearcast advice in any ruling.
In the absence of a code or a regulator for political ads we suggest using common sense in weighing the accuracy of your substantiation. You should, however, publish the source of the substantiation in the ad itself or on the same webpage as your digital ads. If one of our nominated fact checking services find the objective factual claims to be misleading the advertiser should take on board that feedback and consider revising or suspending adverts containing those claims. This is a “proxy” for the role a regulator would / should play when legislation is brought up to date.
Our nominated fact checking services are Full Fact, Channel 4 FactCheck and BBC Reality Check.
This pledge is intended as a starting point. We will update the points in it when we receive relevant feedback, and if emergency electoral law legislation is passed in the next few months.
* We have prioritised transparency in digital ads to avoid what are known as “dark” digital political ads only viewable by the members of the public at whom they are targeted. However, we would welcome advertisers taking this a step further and publishing all non digital paid for adverts also to maximise transparency.