The Birmingham-based firm has been prevented by the ASA from using the advertising again in its current form, which promoted Creation’s personal loan but failed to inform the recipient on the envelope that it contained marketing material.
In the cover letter sent to recipients, the text read: “Stay in control with a Creation Loan Dear… September is a great month to get organised; so whether you’re looking to upgrade your car or consolidate outstanding debts, a Creation Personal Loan could be much more affordable than you think. With loans raging from £1,000 to £25,000, kick start your plans and apply today…”.
Creation responded to the complaint by arguing that the content itself made clear that it was marketing information, whereas the envelope, which was not marked, did not include any information that suggested it was from an official source, was private correspondence and was not likely to have misled recipients about its contents.
However, the ASA stated that the while the envelope itself did not include marketing claims, the direct mailing formed part of the marketing communication, meaning the recipient should be aware of its contents.
The ASA recognised that the enclosed content made clear that it was marketing material from a loans company, but concluded that the inclusion of Creation’s company name and return address on the envelope was not enough to ensure the recipient knew what was inside.
Creation has been ordered to ensure any future direct mailings are made clear from the outset that they contain marketing communications.