Over the past month, a fever slowly took over England as the Three Lions progressed through the FIFA World Cup all the way to the semi-finals for the first time since 1990. Very few would have predicted that the England men’s national team would make it as far as they did through the knockout stages. A perfect example of this is the development of the “It’s coming home” mantra throughout the tournament.

What started out as an ironic and self-mocking use of the hook in Baddiel, Skinner & The Lightning Seeds’ “Three Lions”, developed into an internet phenomenon as the team progressed. Social media became awash with memes, parodies and lip sync videos building hype for Gareth Southgate’s squad.

Hashflags

#ItsComingHome became a hugely popular and trending hashtag across all social media platforms. This was much to the benefit of William Hill who had the foresight to pay Twitter for the right to attach a branded ‘hashflag’ or ‘Twitter Emoji’ to the hashtag.
A hashflag is an image or emoji that appears after a hashtag on Twitter, enabled for specific occasions or events. They appear for a set period of time in which a campaign is ongoing and disappear thereafter. Twitter sometimes provides these of its own accord, for example with national flags or popular/trending hashtags.

Companies can pay for or ‘sponsor’ hashtags in order for their hashflags to appear, for example to promote films or products. Coca Cola was reportedly the first company to pay for a branded hashflag with its #ShareACoke marketing campaign in 2015.

William Hill and #ItsComingHome campaign

William Hill, the self-proclaimed ‘home of betting’, found themselves in an enviable position when they sponsored #ItsComingHome resulting in a William Hill branded football kit emoji appearing next to the hashtag every time it was used.

It should be noted that this was a campaign which included many other hashtags such as #3LionsRoar and #ScratchOfTheDay (which is still active, see above).

The campaign started on 31 May 2018 preceding the “It’s coming home” euphoria that swept the nation at the beginning of July. Therefore, William Hill could not have predicted such widespread use of the hashtag.

William Hill and/or Twitter de-activated the hashflag on 7 July 2018, eight days prior to the World Cup’s conclusion and four days prior to England’s semi-final defeat.

It had become clear that the widespread appearance of the hashflag meant under 18s were – unwittingly – either promoting by using, or receiving by seeing, marketing communications for gambling. There was public backlash against the appearance of the hashflag on Twitter, and criticism of both William Hill and Twitter in the media. The problem was exemplified by the use of the hashtag by the magazine Beano – @BeanoOfficial; whilst their Twitter account seems to be mostly directed at adults, it can be assumed that it will have some audience members who are under 18.

Gambling and marketing communications

UK advertising rules strictly prohibit marketing communications for gambling being “directed at those aged below 18 years… through the selection of media or context in which they appear” (UK Code of Non-broadcast Advertising and Direct & Promotional Marketing, Rule 16.3.13). Whilst no specific complaint was made to the ASA, following the publication of a number of articles criticising the hashflag as inappropriately targeted, it was quickly removed.

Weekly rulings published by the ASA have made it clear that marketing communications on Twitter and other social media platforms need to be appropriately targeted. On Twitter, Promoted Tweets can be targeted by age, keywords and interests. By combining this with monitoring audience statistics across a range of Social Media platforms, companies can prove that their marketing communications are being directed appropriately.
The major difficulty with branded hashflags is that, at the current time, they appear automatically and with no clarity that it could be part of a targeted campaign. Once the functionality is enabled, any user who types the relevant hashtag becomes a brand ambassador for the paying company – wittingly or not.

This is where William Hill went wrong with its sponsorship of #ItsComingHome: the hashtag has broad appeal and resonance for English football fans of all ages, and no specific connection to William Hill or gambling.

Budweiser’s Bud Light campaign

In contrast, consider the #BudLightHouseParty example shown above. This is clearly a marketing communication for Budweiser’s Bud Light alcoholic beer and if targeted at those aged below 18 years would be in breach of UK advertising rules.
However, the key characteristic of this hashtag and associated hashflag is that it is unlikely to reach a wider audience than anyone who doesn’t intend to reference the Bud Light beer brand. If the initial advertising that seeds the hashtag is appropriately targeted then the use of the hashtag (and associated hashflag) is likely to hit the appropriate audience too.

#ItsComingHome, on the other hand, had no obvious connection to the William Hill brand prior to the introduction of the William Hill hashflag.
Although the William Hill sponsorship of #ItsComingHome seemed like intelligent marketing foresight, it unfortunately overlooked gambling advertising rules. However, it provides a good example of the potential pitfalls of using social media to advertise products and services in highly regulated sectors.