The Government’s proposals for the introduction of digital imprints in electoral advertising are disappointing for three reasons, only two of which are obvious.

It’s clear that digital imprints, i.e. the means by which political parties and other campaigners can be identified in online advertising, should be introduced as soon as possible, if not earlier. This plan is simply an extension of the requirement applicable to printed material, one that the Electoral Commission have been recommending for more than fifteen years, and one that was in our original four-point plan several years ago.

That is the first disappointment: this consultation is terribly late; at least three General Elections or referenda have happened without benefit of the increased transparency this proposal would have provided if enacted. 

The above is the first of the obvious disappointments. Still, better late than never.

The second obvious disappointment is that the proposals fail to deliver what voters really want in electoral advertising: not just advertising where it’s clear who is behind it – that is, after all, a bare minimum in any other advertising and anyway required by law – but advertising that does not permit the kind of misleading statements that have so besmirched electoral advertising over at least the past twenty years.

That oversight, or deliberate omission, as the case may be, is an obvious disappointment because the regulation of the content of electoral advertising is an issue on which we have campaigned for some years and because it’s so blatantly the right thing to do – for voters, for politicians and for the whole electoral process and therefore for democracy.

While, as with the other disappointment above, that would appear to be an obvious case, we commissioned YouGov research specifically for this consultation that found that 64% of voters thought it very important that …’it is clear which political party is responsible for an advert’ but that 77% thought that…’political parties’ adverts do not make false or misleading claims.’

This finding, in case it suffers from the inevitable accusation of research findings suiting those who paid for them, is supported by two other pieces of evidence:

‘As with traditional campaign materials, identifying a trustworthy source was important in establishing the credibility of a message. However, although identifying a trusted source helped to reassure participants that campaign material was bona fide, this did not always mean that they believed the information contained in the message. This is because there is a distrust of campaign messages and statements made by politicians more generally.’

And

‘The core concern for participants throughout the research was the believability and trustworthiness of the content they consumed during election campaigns.’ (emphasis per the research document).

  • A study we commissioned in December 2019, which found that 87% of voters thought that ‘it should be a legal requirement that factual claims in political adverts must be accurate.’ We conducted a very similar study in December 2018, when the level was 83%. Both pieces of research from YouGov. 

The third disappointment is rather less obvious. This should be an entirely straightforward exercise: an extension of the identification regime that exists in electoral print advertising into the online space. Such an exercise should surely not tax, as it were, the Cabinet Office? 

We do not particularly recommend the reading of the consultation document itself, linked above. It’s not exactly a page-turner, but these processes are not intended to produce a rattling good yarn: just some solid evidence-based thinking, clearly articulated, on how the government plans to go about this workaday exercise. 

Where it deals with the matters specific to the online identification process that it sets out to deliver, the document fails on four counts: it fails properly to define two different aspects of scope, it practically guarantees inconsistency in application, it pays no attention to what voters want in execution of this process, and some aspects of its drafting should make the Cabinet Office blush if they were capable of displaying such humility. You can read our full response, should you wish, here.

But the deep and central flaw of the proposals in this consultation is that it is simply not possible to address the scope of the imprint extension proposals and the maelstrom of advertising in the digital world without recognizing that who advertisers are is inevitably and directly connected with what they say. Indeed, what they say often identifies who they are. It is only the combination of regulatory measures – identification and material content – that will deliver to voters and to democracy.  

At least the government might have got the Identification measure right, but on the evidence of this consultation, apparently not even that could be managed.

The Coalition For Reform In Political Advertising


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