This note sets out our views on the issue that has become something of an online debate after our tweet that we regarded the Lib Dem letter to voters in Somerton and Frome as a ‘terrible’ campaign.
To those who may have missed this edifying exchange, a reference to the campaign material is here.
Before we focus on the letter in question, a few points by way of context:
- Our background is advertising. Our founders and directors worked for a very long time in the industry at a senior level; some of them continue to do so. We have been and remain closely involved with advertising’s regulation and have a comprehensive understanding of the rules – both self-regulatory and statutory – that apply in the commercial sector. We know what kind of advertising works, what consumers respond to, and what they don’t. If we have learnt only one thing in long careers, it is to respect consumers.
- We have been campaigning for some four years now on electoral advertising. Lengthy and detailed documentation that reviews electoral advertising across those years can be found here. Our objective is that political parties should agree a code of conduct for factual content in electoral advertising and allow its management by established authorities, e.g. the ASA, UKSA, Electoral Commission and Ofcom. This goal is in line with the House of Lords Democracy and Digital Technologies Committee recommendation of June 2020, to which we gave evidence.
- We are politically neutral. We don’t even know how or whether our colleagues vote.
The point of the above is to make clear that we know what we’re talking about and we do so from a politically non-partisan perspective. We accept that we have expressed strong views about electoral advertising in the U.K. and of course we don’t expect universal agreement. What we hope for, rather than expect, is a reasonable debate or exchange on the issue of the standard of electoral advertising in the U.K. and whether it is sufficiently accurate, transparent and honest.
This leads us to the specific issue of the Lib Dem letter distributed in the Somerton and Frome constituency that sparked recent interactions. This election material, our reaction to it and the surrounding debate also require framing, as follows:
- Electoral advertising in the U.K. is of great concern to voters. Electoral Commission (EC) research from the 2019 General Election reports: “People were concerned about misleading campaign techniques from across the political spectrum, and bias in the media. We received a large number of complaints raising concerns about the presentation, tone and content of election campaigns”. It is notable that not a single reaction from the ‘pushback’ from those who commented on our review of the Lib Dem letter addressed the content of the material from this voter perspective. We should be aware of the context in which this material operates: people strongly dislike manipulation in political campaigning.
- The Liberal Democrats have a record of grossly misleading election material. We have reported on this aspect of the party’s behaviour ad nauseam and it’s widely recognised well beyond our own limited scope that some features of the way in which the Lib Dems represent themselves in election scenarios are reprehensible. This is also true, sad to say, of all major political parties, but the Lib Dems have a special expertise in misleading and manipulative appeals to voters, often expressed in ‘bar charts’ that to many commentators are risible, but to us are deeply unfunny because their objective is to present voters with information that is frequently inaccurate or misleading or both. It’s curious, to ourselves at any rate, that a political party that has the opportunity to present itself as different and better feels the need in its communications to mire itself in electoral material that is certainly no different, definitely no better and probably rather worse than even desperately low prevailing standards. We make this point as it has bearing on judgments of intent.
The letter from the Lib Dems that is the subject of this note is represented as from a member of the Green Party and recommends that recipients vote Lib Dem, not Green. The letter carries statutory identification requirements (RPA 1983, PPERA) in small type at its base.
We hope it’s reasonable to summarise some online reaction as follows:
- it is a perfectly legitimate tactic to deploy a member of an opposing party and the ID requirements were met. The letter is compliant; there’s nothing to see here.
- Our original tweet did not suggest that the letter breached rules. It said that the campaign is ‘terrible’ and that the Lib Dem campaign machine is ‘endemically dishonest’. We have a great deal of evidence for the latter statement.
- We think the campaign is ‘terrible’ for two reasons, principally. Voters distrust political communication generally and in particular they distrust the integrity of source (EC passim). The technique that’s deployed in this situation is the kind that most voters very much dislike. Even the term used to describe it – ’squeeze messaging’ – indicates the attitude of the promoter to the voter. So it’s our view that it’s terrible in part because this kind of tactic offends voters;
- The second reason is that we believe the approach takes advantage of poor regulation. The statutory ID requirements do not stipulate the size and positioning of the source of the communication. In several regulation-sensitive sectors in commercial advertising, alcohol and cars for instance, there are specific requirements for the size and placement of mandatory messages. Additionally, the ASA publishes guidance for all forms of advertising that ‘Qualifications should be clear and legible; they should be prominent enough to capture a consumer’s attention in a given media or ad format.’ It’s our view that all political parties take deliberate advantage of the law’s shortcomings and ‘bury’ their identification. In this case, that permits the reading of this letter as from an ‘unmanaged’ Green Party member.
The truth of this situation is that the Lib Dem letter is not the worst that they, or others, have delivered. It’s pretty terrible, but we must admit we’ve seen many that are rather more offensive. What interests us most about this incident is that the Lib Dems, and no doubt other political parties, can see nothing offensive or underhand in this kind of tactic and perhaps that’s the real difference between the ‘sides.’ It is a difference in philosophy or perspective between the way in which political parties see their work and how we, together with many others (most voters, for starters), come at it. To politicians, the test seems to be whether campaigns can ‘squeeze’ votes out of people and they probably don’t care about and certainly don’t appear to take into account the very low regard that voters have for the way in which they campaign. We prefer the idea that voters might be persuaded differently and better.
We rest our case. Nobody ‘wins’, of course. The only big loser is the voter who must endure the continuing barrage of unregulated, unwelcome and often offensive campaign material.