Annex 1: case studies

• Author: Jordan Hill - Malin Carlberg - Richard Procee - Iva Plasilova - Marion Goubet
• Pages: 101-119

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Directorate-General for Communications Networks, Content and Technology

ANNEX 1: CASE STUDIES

Each case study was developed using desk research and several interviews. The findings

were then written up as 2-3-page mini reports. The most important findings have been

integrated in the main analysis of this study.

The table below provides an overview of the selected topics, their reasoning and the type

of stakeholders targeted for interviews.

Table 6: Case study selection

Topic

Reasoning

Targeted stakeholders

Issue-based

advertising

While there is no problem in defining what is political-

based advertising, with issue-based one it is not so

easy as there are often national, even regional

nuances that need to be considered. This case study

explores what would be the minimum measures

defining issue-based advertising.

• National regulators

• Academics

• Civil society

• Signatories

KPIs/Metrics

Looking at the current reporting requirements, how

could these be improved and harmonised across the

reporting organisations. What constitutes a strong

KPI in this area? Should these be set on a European

or national level. What is the best way to monitor

specific harmful activities, e.g. is it better to delete

fake accounts or monitor their behaviour to see how

they develop?

• Signatories

• Academics

• Researchers

• Civil society

Data

requests

What are the main barriers for researchers to get

access to the data th

ey request, and whether a

common template for such requests could be

established?

• Researchers

• Academics

• Signatories

Partnerships

with fact-

checkers

How effective are the se partnerships in verifying and

promoting trusted content?

• Fact-checkers

• Signatories

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Directorate-General for Communications Networks, Content and Technology

Case study on Issue-Based Advertising

This case study goes deeper into the topic of ‘issue-based advertising’ as part of Pillar II of

the Code of Practice.

Focus

There are specific challenges related to this topic for platforms, EU institutions and Member

States that require careful consideration in the context of the Code itself and any future

iterations. The data sources for this case study are largely news articles, platform reports

and the Code itself, complimented with further interviews of academics, regulatory agencies

of member states and civil society organisations.

Current situation

At present there is no universal definition of ‘issue-based advertising.’ With this in mind, the

below table draws together various defining characteristics of issue-based advertising, as

distinct from political advertising. The Code itself placed the onus squarely on the platforms

to coordinate an accepted definition, similarly, the High-Level Expert Group on

Disinformation did not clearly define ‘issue-based’ as distinct from ‘political advertising’.

Table 7: 'How to define issue-based advertising'

The Cambridge Dictionary defines issue-based advertising as ‘advertising that is not intended to sell a

product or service, but rather to change people’s opinions or behaviour.”212

Of course, issue-based advertising has been targeting consumers long before the rise of social media,

for example the 1986 ‘Don't Die of Ignorance’ Aids campaign in the UK.

The key distinction to make is that, in contrast to political advertising, issue-based adverts do not have to

be linked to politics, politicians, or electoral processes and are not explicitly connected to an ideology.

Recent topics on social media which can be categorised as ‘issue-based’ include:

• Health, for example the anti-vaccine movement.

• Environment, for example palm oil and habitat loss of Orangutans.

• Conflict, for example the humanitarian crisis in Yemen.

The main challenge, therefore, with regards to issue-based ads, as opposed to political advertising, is

that issues are constantly changing and gain momentum internationally while still largely being framed in,

and defined by, national context.

The task of defining and identifying them is also made more challenging because they often lack the same

telling and consistent indicators there are for political advertising, such as explicit reference to elections,

candidates and political parties, which are universal across the EU.

212 Cambridge Dictionary, Meaning of issue advertising in English, Cambridge Dictionary online. Accessed on the 4th March

2020 via https://dictionary.cambridge.org/dictionary/english/issue-advertising .