Review of social advertising on Russia TV channels
The Public Chamber Coordination Council for social advertising and communication is looking at whether television channels have created the required commissions to assess social advertising. It is also considering further changes in this area.
Commissions – formal and actual
In April 2018, a meeting of the Council discussed the creation of television channel commissions for social advertising. The purpose of the commissions was to make the process of assessing NGO publicity campaigns more transparent. The Ministry of Digital Development, Communications and Mass Media announced in an official letter that commissions had already been created at the All-Russia State Television and Radio Broadcasting Company (VGTRK), the Star (Zvezda) TV channel, Public Television of Russia (OTR), and Channel One.
In August 2018, a working group of the Coordinating Council undertook to monitor the commissions. The group checked whether television channel websites provided conditions for the placement of NGO advertising, along with contact details for their commissions. If telephone numbers were given, members of the working group called to confirm whether the online information was correct.
The monitoring revealed that only Zvezda and OTR had provided full data about their social advertising commissions.
The Channel One website suggested sending an enquiry to the advertising department, and VGTRK replied that they had no commission for social advertising. The working group also approached NTV, MATCH-TV and the Carousel TV channel – where no contact details for special commissions were available. Channel Five requested an enquiry by e-mail, while the TVTs website failed to provide any information.
Introducing social advertising
By way of trial, the Coordinating Council has suggested that charities attempt to place advertisements on television with the help of commissions that already exist. Social advertising videos must initially undergo assessment at the Public Chamber. Videos from two foundations – ORBI and Charity address (Adres miloserdiya) – are currently waiting to be examined. Once specialists have provided a report the charities will send it on to television channels, along with their promotional video.
The assessment includes a study of whether the video is in line with the law on social advertising, and examines its content and quality. However, no formal procedure for the assessment has been agreed to date, says Vladimir Vainer, Director of the Gladway Foundation for the development of media projects and social programmes, and Creative Director of the Grand Prix Centre for advertising research.
‘If we formalise the assessment, the process will take a maximum of five days. But for the time being nothing has been finalised in writing. At the moment we are looking at whether substantive indicators of social advertising are being observed, and making hypothetical legal evaluations,’ Vainer explained.
The Foundation for Children in Difficulties will also attempt to submit advertising that will meet TV requirements. At present it is setting up campaigns on responsible fatherhood and adolescent aggression. The organisation’s staff say that they make no appeals for funds and their videos do not include the foundation’s logo, in order to avoid possible rejection.
‘The most important thing is that, during the course of this trial, we should not lose our sense of who is responsible for the information submitted,’ Vladimir Vainer says. ‘In future, we would prefer it if we did not have to lose our logo, contacts, and source when we advertise. These details are important to prevent any blurring of our message and to enhance our call to action.’
In order to support NGO advertising campaigns, the Higher School of Economics is running a ‘LIME-accelerator’ (‘LIME-akselerator’) competition. Between 3 September and 10 October, NGOs are invited to submit promotional scripts on behalf of their organisation. Five winners will be selected by students at the National Research University Higher School of Economics and the organisational committee of ‘LIME-akselerator’. Social advertising videos will be made to promote the winning organisations.
Gyuzella Nikolaishvili, Director of the Laboratory for Social Advertising, says that some TV channels are reluctant to take on social advertising because of tax risks involved. These are particularly high if the advertising is in any way linked to gathering funds or to paid services. The Human Resources Director of Gazprom-media, Erika Kuyantseva, says that the problem could be resolved if TV channels called for specific documentation to be submitted.
‘We have put together the list of documents we want to see when we start working with a foundation, and a further list of documents required by way of evidence of what has been achieved. It is important that funds are properly used, that money shouldn’t simply be transferred abroad and that, for example, we should see a certificate indicating that specific medical treatment cannot be provided in Russia. It is helpful to have a coherent, integrated package of documents. Perhaps this should become standard practice when foundations submit an advertisement, along with collected donations, to a TV channel,’ Kuyantseva added.
It is also worth noting that commercial channels have Key Performance Indicators (KPIs) and are obliged to assess the success of their projects.
In the first instance, NGOs have been advised to consider whether a video they produce is suitable for the target audience of the given TV channel, and to think about the purpose of their advertisement and its anticipated outcomes.
The Coordinating Council and the Lawyers for Civil Society association are working together on introducing legislative changes. As Gyuzella Nikolaishvili points out, priority must be given to developing a satisfactory definition of social advertising in general.