The UK’s advertising regulator, the Advertising Standards Authority (ASA) has banned a sales promotion for “pressuring” customers into purchasing cosmetic surgery. The email advert, produced by deal-of-the-day discount provider Groupon, offered consumers “£1,999 instead of £5,000 for Cosmetic Surgery”. Highlights included “General Medical Council-registered plastic surgeon” and “private hospitals”. Customers clicking on the email were redirected to the Groupon website which featured additional fine print stating purchasers “Must be 18 or over. All treatments subject to initial consultation”. The Independent Healthcare Advisory Service and a viewer complained that the offer was irresponsible because it encouraged customers to hurry into a decision to purchase cosmetic surgery. In response, Groupon said that they did not believe the offer encouraged frivolous or rushed decisions. The offer was available for 24 hours, but that was their business model. Groupon also argued that the offer was only available to those over 18 years, treatments were subject to a consultation, and a refund was offered if customers were found to be unsuitable for treatment. Further, customers were able to speak with health professionals at the clinic and the email provided details of the surgeons and a link to their General Medical Council (GMC) accreditation.
Upholding the complaint, the ASA noted that while Groupon had taken reasonable steps to ensure customers had the opportunity to get post-purchase advice and were encouraged to seek independent medical advice, the British Association for Aesthetic Plastic Surgeons (BAAPS) code prohibits adverts which offer discounted surgery linked to a deadline. Adverts offering discounts also went against the GMC’s good practice guide. The ASA also considered that the decision to undergo physically invasive procedures required substantial consideration, and they understood from BAAPS that candidates normally required multiple consultations before proceeding with surgery. The 24-hour window therefore offered a very limited timeframe, which would pressure people into making a decision.
Accordingly, to the view of the ASA, certain “purchases” are simply not suitable for time-limited sales promotions which, by their very nature, encourage customers to make impulsive purchasing decisions.