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Glowday, the ASA and advertising Botox

Glowday had one complaint about one article and one landing page which the ASA decided were advertising Botox.

For the full account and Glowday's response, read on!

We firmly maintain our stance that we were not advertising Botox. Nor were we praying on women's insecurities.

Glowday had one complaint from one competitor about one article and one landing page and if you take the time to read the article, you will see that there was no mention of the price of the treatment, a number of other treatment options were discussed and there were no outlandish claims about the treatment. Additionally, there is no way to book Botox or purchase Botox via Glowday.

If you wish, you can read a full account, including the two articles which were the basis of the complaint, here and decide for yourself.

There are a number of notable learnings we have taken from this ridiculousness:

1. The ASA are selectively reactive and not remotely pro-active.

If you thought the ASA are out there actively policing adverts, they aren't. There are millions of very obvious and flagrant breaches of advertising standards by many businesses, including those "who should know better" who get a disproportionately high share of voice (and web traffic and paying customers) as they consistently disregard the guidelines. Why? The commercial gain is greater than the consequence of any complaint being upheld.

How do we know this? When we provided the ASA with 50 websites ranging from the UK media, chains like SK:N and therapie - arguably Allergan’s largest European customers, numerous beauty booking platforms, non-statutory registers, prominent aesthetic clinics, KOLS and high profile practitioners linked to industry bodies and businesses, their response was because Glowday is deemed a competitor (to each of the 50 businesses ??), it is for Glowday to follow the IRP process by writing to each one before they would take action. Or because the websites are editorial it's not within their remit.

After posting about the ruling on Instagram, I had a number of practitioners message to say that they too had reported breaches to the ASA and nothing was done.

I suspect that, as gets more website traffic than any other aesthetics-focused website in the UK, we're a good target to get others to fall in line and self-police.

2. Botox is to anti-wrinkle treatments, what hoover is to vaccuum cleaners.

Glowday, and its qualified, trained and accountable practitioners are hamstrung when it comes to educating consumers about Botulinum toxin treatments, because those same consumers have adopted the term Botox to mean the treatment.

The public don't Google "What are the risks of anti-wrinkle injections?" they search "Is Botox dangerous?". They don't search "Where can I have treatments for lines and wrinkles?", they Google "Where can I have Botox?"

When consumers use the word Botox, they aren't referring to the drug, they're referring to the treatment. Like when you say you're going to "hoover the house" you might be using a Hoover, but equally you might be using a Dyson. Hoover has become the noun and verb. Similarly, botox is

This poses a significant patient education challenge. How can you educate the public on how to seek safe anti-wrinkle treatments, using Botox, or any other brand of toxin, if you can't actually use the word they are putting into search engines?

3. The systems currently in place disadvantage accountable healthcare practitioners.

Unaccountable, non-medic injectors can flagrantly advertise Botox, Kenalog and other prescription only medicines. They can do so as they have no Statutory Body registration to protect. Healthcare practitioners are fiercely protective of their registrations and will (on the whole) do their very best to comply.

Where practitioners have no registration to protect, and the consequence of not adhering to the rules is being asked to remove a post or reword a webpage, they have significantly less to lose and more to gain.

This disparity in accountability has fuelled the rise of mis-information, has amplified the voice of unregulated practitioners, whilst suppressing the voice of regulated injectors and has disproportionately accelerated the growth of the non-medic segment of the industry.

4. The word Botox is regulated, but who can administer the drug Botox is not!?!?

Perhaps the craziest thing about all of this, is that regulated healthcare practitioners can't use the word Botox to educate their patients, but unregulated lay injectors are legally able to inject the actual drug into people...after a days training.

In summary, we think the whole thing is a nonsense.

The ASA is out of touch and is simply unable to police the advertising of Botox. They lack the technology, the resource and the appetite, so make an example of reputable, ethical businesses like Glowday.

If the ASA only respond to certain complaints made, they have no chance against the hundreds of thousands of websites appearing in Google “Botox” search results, the 16.1m #BOTOX on Instagram and the 6 billion views of #BOTOX onTikTok.

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