SAFE Framework: the 4 principles for HMG Brand Safety
The SAFE Framework introduces new standards for digital brand safety in HM Government advertising.
It is underpinned by 4 core principles:
- safety and suitability
- ads context
- freedom of speech
- ethics and enforcement
- Categorisation of digital environments
- What are the SAFE principles?
- Cross-channel governance
- HMG Inclusion list
- Campaign-specific flexibility
HM Government (HMG) advertising engages millions of people through billions of advertising impressions every year in vital and important campaigns such as public health messages, recruitment for our public services, and blood donation.
As Government Communication Service (GCS) continues to utilise digital markets and platforms for campaigns, we must safeguard government advertising and messaging from appearing in inappropriate or potentially harmful environments. The SAFE Framework provides the toolkit for GCS Campaign Team Leads to assess digital environments, introducing minimum required standards and a risk-based approach to HMG advertising, that will help GCS demonstrate responsible use of taxpayer’s money, build public trust, and help raise standards across the wider industry.
It has also been designed to be adaptable and flexible, taking into account the breadth of HMG campaigns, the multitude of audiences, and the plurality of environments available online. Where campaigns have a requirement to appear on a website or platform that may pose some brand safety risks, assessments will weigh the contextual rationale versus the identified risks. Section 6 provides more detail on this Campaign Specific Process.
2. Categorisation of digital environments
The SAFE Framework has been developed to be applied across different digital environments for the first time. The term ‘digital environment’ is used here to denote all digital services that can serve digital ads, such as for example online platforms, social media networks, forums, websites, apps, streaming video and audio services. How a brand safety assessment will be implemented will depend on the categorisation of a digital environment which will fall into two main categories, depending on its advertising monetisation strategy. These are:
Funding Content Creators (FCC)
Platforms and buying models where HMG advertising spend is shared with the content creators partially or in full. For example, the publishers in programmatic buying or video creators on YouTube and Twitch (a live streaming platform for gamers).
The FCC category poses the highest risk to HMG brand safety and requires an extra level of care and monitoring, as brand safety breaches in this category will directly fund the creators of the inappropriate content (such as when HMG advertising inadvertently appeared alongside extremist content on YouTube in 2017, which led to HMG stopping its advertising on YouTube until appropriate safety mechanisms could be provided).
FCC categories will therefore be subject to a higher level of scrutiny, and campaign-specific requests (see section 6 of this publication).
Funding Platform Only (FPO)
Platforms and buying models which do not share the advertising revenue with content creators, or do not have content creators, and instead optimise ad placement across their platform according to user behaviour, location, or time of day. These platforms usually do not offer advertisers and agencies much control over the adjacent content or context in which the advertisements are placed, for example in social media ‘feeds’ or in digital out-of-home.
The FPO category is composed of quite varied environments, each with their own considerations, which need to be suitably assessed. GCS will continue to proactively work to ensure brand safety controls and processes are implemented amongst these platforms to deliver the highest levels of brand safety for HMG.
3. What are the SAFE principles?
We set out the core criteria for each of the 4 SAFE principles that will be used when assessing the brand safety risk for HMG digital advertising.
S – Safety and suitability
First and foremost is to establish the baseline brand safety standards of the environment. Safety checks involve ensuring that content within the environment is not likely to endorse or promote any illegal activity, harmful behaviours, and attitudes, or cause serious offence to individuals and/or protected groups.
This is considered as the minimum required criteria for all HMG advertising.
Safe environments for HMG advertising must have:
- no hate speech, extremist, anti-democratic messaging, and no content that could be perceived as offensive to protected groups in society
- no promotion of harmful behaviour or incitement of harmful behaviours towards others
- no enactment, endorsement or promotion of illegal activity
- no recent history of monetising unsuitable content, or funding undesirable or banned individuals/organisations
Once an environment has been established as safe, the suitability needs to be assessed to ensure that the environment is appropriate for HMG advertising. This includes considering the message of the campaign and the contexts that could cause reputational harm or embarrassment to HMG.
The suitability criteria will vary depending on the nature and seriousness of a campaign. For example, a climate change or environmental campaign appearing next to a climate change denier’s content, would not be acceptable, but EU Exit campaign material appearing next to anti-Brexit content may be deemed as ‘embarrassing’ but acceptable.
As part of establishing suitability, GCS accepts that there will be some categories of content that are not generally suitable for HMG while recognising the rights of other advertisers to advertise against this kind of content.
Important factors to consider for suitability include:
- no party political funding
- no explicit sexual, drug or violent content (unless it relates to the campaign topic, see section 5, campaign-specific process)
- clear and named ownership of the platform or publisher
- campaign teams should also consider the context of the campaign: is there satirical or political content that may not be suitable for the campaign to appear alongside?
A – Ads context
It is important to HMG that adverts appear in efficient environments that provide value for taxpayer money, with the highest chances of being seen, heard, and acted upon by real people. A recent study found that adverts on high-quality websites are 74% more likeable than the same adverts on lower-quality sites. HMG advertising must appear in environments which promote good user experiences, make provisions to limit advertising ‘bombardment’ (where relevant), and which have a high quality of advertising content. GCS also remains committed to combating ad fraud and the ambition of full viewability through our media partners.
Ads environment criteria for HMG advertising include:
- low levels of ‘ad clutter’ (as established by technology and human verification)
- Ad clutter assessment includes considerations such as the number and placement of adverts, the ads-to-content ratio and appearance across user devices (where applicable)
- frequency management, low levels of ad cycling, and/or no auto-reloads
- high levels of viewability and/or exposure by real people
- low level of ad fraud and active measures to minimise fraud, coupled with suitable arrangements for refunds to the advertiser where ad fraud is identified
F – Freedom of speech
HMG encourages freedom of speech and high-quality journalism online for a healthy and flourishing democracy.
Essential to this is safeguarding the rights and protections of individuals and minority groups online. User-generated content unfortunately has the potential to be abused, and such content can be harmful, violent and offensive.
To support respectful and constructive environments for public interaction, HMG must advertise where there are clear:
- guidelines for user-generated content that set out appropriate standards and a code of conduct that protects individuals from harmful content
- active monitoring of the user-generated content, and/or that users are able to report inappropriate content
- the actual implementation of removing content that breaches the guidelines
As part of its commitment to high-quality journalism and free speech, HMG also recognises the role of the press in providing important checks and balances on power through investigative journalism.
To support high-quality journalism, HMG should seek to advertise with news publishers that:
- uphold the highest standards in editorial codes of conduct
- adhere to relevant regulatory standards such as those set by Independent Press Standards Organisation (IPSO), or an alternative code of conduct that protects the rights of individuals and encourages ethical journalism
- has no history of publishing or broadcasting disinformation, with the intent to deceive
E – Ethics and enforcement
HMG advertising must only appear in environments that adhere to the highest regulatory standards. It is important that digital environments are able to adapt to changing regulations and legal guidelines to ensure that users, viewers and listeners are protected from harmful content. They must also demonstrate a responsible and ethical use of data, which respects users’ privacy and rights online.
To demonstrate regulatory and data best practice, environments should:
- respect users’ consent online and demonstrates positive movement towards full legal data compliance
- adhere to relevant regulatory standards, for example, the Office of Communication (OFCOM) and the Committees of Advertising Practice (CAP)
- have a commitment to cybersecurity, such as ensuring domains have SSL certification (where applicable)
- protect government (and other advertisers) from appearing alongside content they do not wish to appear against, for example by supporting the implementation of content verification technology in real-time to monitor and block unsuitable content
- demonstrate transparency and responsibility in its selling of advertising space, and conform to the reasonable expectations of the buyer
- protect children online through age appropriateness best practice, where relevant, such as the implementation of age verification systems
4. Cross-channel governance
For the first time, the SAFE Framework and principles will provide guidance for HMG digital advertising across a wide range of digital platforms, helping to improve brand safety standards and awareness across HMG.
The SAFE principles should be applied across the following digital platforms:
- websites and apps
- social media
- online video channels
- video on demand (VOD) channels
- digital audio channels
A toolkit of SAFE assessment forms will be made available to campaign teams to assess associated risks of environments. These will be tailored to the channel being assessed.
For those platforms that are categorised as FCC (Funding Content Creators), central governance will be maintained by GCS of digital platforms that have been approved for HMG advertising. For platforms categorised as FPO (Funding Platforms Only), government organisations will be expected to apply and consider the SAFE principles for internal best practice and governance.
5. HMG Inclusion list
HMG operates an inclusion list of websites for programmatic advertising that meet the existIng HMG acceptable standards. This core list will only include websites that adhere to all brand safety principles of the SAFE Framework’s programmatic criteria and have no perceived brand safety risks, as this list must be suitable for the breath of HMG digital advertising across all of the various different campaigns and government organisations.
Publishers must meet the core SAFE principles to be eligible for the HMG core inclusion list. Government organisations can also use this list to inform decisions when entering direct buys with publishers.
However, HMG advertising can still be run in environments that do not meet all channel-specific criteria, so long as a risk assessment has taken place – see the next section: Campaign-specific flexibility.
6. Campaign-specific flexibility
As previously referenced, HMG communicates with the public on a wide array of topic areas, which may well have different brand safety requirements. The SAFE Framework has been developed to provide core brand safety for all campaigns, however we also recognise the need for tailoring to specific campaign context and audiences to drive government outcomes.
The SAFE Framework therefore incorporates a Campaign Specific Process for programmatic advertising, that will allow government organisations to request changes and additions outside of the core HMG Inclusion List, for specific campaigns.
This process incorporates a SAFE Assessment form that the media buying agency or government organisation must use to assess a digital environment against the core brand safety principles. This form constitutes a step-by-step risk assessment and allows provision for details on the contextual rationale for using it, and weighing it against the risks.
By applying the new SAFE Framework to government digital advertising we will continue to ensure the highest standards of brand safety for HMG advertising online. This will protect the HMG brand and make sure that government messages are trusted by the public, while continuing effective reach, delivery, and impact for all government campaigns.