Advertising and sponsorship policy

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2 Policy title: Executive summary: This policy provides guidance to East Cheshire NHS Trust staff regarding allowances for advertising and sponsorship in situations when the trust is looking at ways to generate extra income to improve its services, facilities or events. All adverts and sponsorship must comply with relevant regulations and the basic principles of advertising legal, decent, honest and truthful. Third party advertisements and links to websites where goods and services are advertised do not mean the trust endorses or recommends the advertiser s goods or services. Nor is the trust responsible for the quality or reliability of the product or services offered but it will never knowingly allow sponsorship or advertising which is untrue or fraudulent. Supersedes: N/A Description of N/A amendment(s): This policy will impact on: All departments within the trust who work in conjunction with sponsors or advertisers. Financial implications: Advertising and sponsorship should be regarded as a way to generate income and therefore have a positive financial impact. Policy Area: Trust wide Document Reference: Version Number: 1.2 Effective Date: Issued By: Director of Review Corporate Affairs Date: and Governance Author: (Full job title) Fiona Doorey Head of Communications and Engagement Impact Assessment Date: 30/06/14 30/06/17 19/06/14 Consultation: Director of Governance Approved by Director: Received for information: APPROVAL RECORD Committees / Group AD Group Governance Managers Group OMT members / service line heads Director of Governance Date 23/06/14 Virtual 23/06/14 By for approval 25/11/14 2

3 Contents: Page 4 1 Policy statement Background and document purpose Scope and readership 4 2 Sponsorship and advertising Points to consider Advertising Space Principles and controls for advertising and sponsorship Authorisation Prohibited products, services and advertisers 7 3 Advertising codes of practice and content 7 4 Promotion in public areas General advertising trust wide Posters and notices in staff only areas Website advertising Display stands and exhibitions Exceptions 8 6 Disclaimer 3

4 1. Policy statement 1.1 Background and document purpose East Cheshire NHS Trust is committed to providing consistent standards of service for patients and staff. To help improve services, facilities or events the trust will consider ways of generating income through advertising and sponsorship opportunities. This policy provides guidance to East Cheshire NHS Trust staff and third party organisations regarding allowances for advertising and sponsorship in suitable situations and circumstances. All adverts and sponsorship must comply with relevant regulations and the basic principles of advertising legal, decent, honest and truthful. 1.2 Scope and readership This document is to be read by any individual or organisation wishing to understand the policy for East Cheshire NHS Trust regarding advertising or sponsorship within the trust. This policy must be read in conjunction with the Corporate Governance Manual relating to corporate sponsorship and hospitality. 2. Sponsorship and advertising The public will make assumptions about who benefits most from sponsorship and advertising transactions, and about whether East Cheshire NHS is choosing to endorse the activity or values of the sponsor or advertiser. For these reasons some consideration outlined below must be undertaken prior to any sponsored activities or selling of advertising space. Sponsorship refers to an arrangement where the NHS receives financial support or support-in-kind in return for the rights to public association with an activity or property. For example, a local company sponsoring an NHS staff newsletter or staff awards ceremony may provide free printing services directly linked to the event in return for logo rights. Advertising refers to the direct promotion through an agreed rate, of the organisation advertising with the NHS and may take the form of an advert on the website, in a staff magazine or newspaper. To discuss these rates please contact the Communications and Engagement department on Points to consider: NHS organisations may enter into commercial sponsorship arrangements. However, they (as with other communications partnerships) should avoid entering into arrangements with organisations perceived to be in conflict with health, for example tobacco and alcohol companies, specific No Win No fee advertising, personal injury lawyers and claims management companies. (A full list an be found in section 2.5) NHS organisations need to ensure they are not put under any undue obligation by a sponsor (or that they become open to the accusation), that core business functions are not affected and that they remain impartial. In every situation a written contract should be put in place detailing what the company expects from the trust and what the trust expects from the company. Once produced this needs to be signed off in accordance with the trust s standing orders and standing financial instructions. The sponsor s support should be seen as adding significant benefit to an existing health promotion messages, campaign or event. 4

5 There should be no overt commercial advantage to the sponsor in terms of the direct sale of products or brands as a result of their association with the NHS. Their involvement should be seen as secondary to the aims of the NHS. The risks of being overly dependent on funding for a project include the possibility that the sponsor withdraws support. Organisations should consider how the project would be funded if this happened. Organisations should make a judgement on the time taken to manage the sponsorship against the potential benefits. Do not enter a partnership with a sponsor if their practices conflict with NHS aims and objectives or bring the hospital or the NHS into disrepute, nor any products or services associated with unhealthy lifestyles. 2.2 Advertising space Selling advertising space for example, on the back of hospital appointment cards, on plasma screens or in other NHS-owned spaces is a straightforward transaction. However, the public will make assumptions about the transaction and so consideration should be given to the following: Who will see this advertising, and what message does it communicate about the relationship of the NHS to the advertiser? Have you compared the costs (time, resources etc) of selling advertising space to the benefits? Are the benefits sufficient to justify the risks? Do you risk losing control of the process by working with a third-party? A written contract should be put in place and you should consider excluding certain types of advertiser from this (eg. tobacco, alcohol, no win, no fee solicitors, personal injury lawyers and claims management companies) Where is the advertising space to be sold for example Retail table space in hospital corridors, poster sites, newsletters, leaflet distribution and will the positioning of the advertising have an impact on accessibility, health and safety and patient care. Advertising and sponsorship is charged at a disclosed fee. This is not a charitable donation. However advertisers who pay for advertising may also choose to make a charitable donation to the trusts charity ECHO if they wish to do so. This is not a specified amount. To discuss these rates please contact the Communications and Engagement department on Principles and controls for advertising and sponsorship East Cheshire NHS Trust is not opposed in principle to accepting sponsorship for services, facilities or events, displaying or running paid for advertisements within the hospital or trust publications, if it is deemed to benefit the trust. Advertising displayed anywhere in the hospital and in any trust publications will reflect our core values and objectives. The look and feel of advertisements from any source be that a private individual or large corporate company will be professional and sympathetic to the caring environment. Care needs to be taken when considering advertising services from companies in competition with the services East Cheshire NHS Trust provides. 5

6 The trust does not therefore take a white listing approach (which is when permitted advertising is defined) but rather follows a black listing approach (which is when the basic assumption is that advertising is permitted unless it falls into a number of prohibited categories, as defined in the chart in section 2.5). The policy for advertising and sponsorship within the trust includes advertisements displayed in; public areas (including notice boards), within patient information, all published literature (including newsletters), display stands, bedside TV, plasma screens, website, exhibitions and all relevant marketing collateral (including posters, leaflets, giveaways, mats, filming). Space taken by a third party to sell products in the trust is a further form of advertising. To discuss these rates please contact the Communications and Engagement department on Authorisation All enquires regarding advertising or sponsorship must be referred to and authorised by the Head of Communications and Engagement and where appropriate by the legal services department. All contracts for advertising and sponsorship will be managed centrally by the Director of Finance to ensure that the best terms are negotiated, that Standing Financial Instructions (SFIs) are not breached and ensure continuity and consistency. The Head of Communications, Engagement and Marketing will review, approve, reject or sign off all advertising copy before any material is sent for printing or before any advertisement is displayed in any part of the hospital. In all circumstances the Head of Communications, Engagement and Marketing retains the right to reject any advertisement or editorial relating to an advertisement. Where departments are approached directly for sponsorship and advertising purposes or where they are holding an event which requires sponsorship these principles still apply and the department must inform the Communications and Engagement Department before approaching organisations. It may be necessary to request references from existing clients. All advertising and sponsorship generated income is payable to the trust via an income subjective code within each departments cost centre. 2.5 Prohibited products, services and advertisers Third party advertisements and links to websites where goods and services are advertised do not mean the trust endorses or recommends the advertiser s goods or services. Nor is the trust responsible for the quality or reliability of the product or services offered but it will never knowingly allow sponsorship or advertising which is untrue or fraudulent. The trust has a highly-valued reputation as a provider of safe, sustainable, quality and professional care. The trust s reputation and core values must not be compromised or put at risk by association with third party organisations advertisements or sponsorship. For this reason, there are specific categories of products and services which may not be promoted, sponsored or advertised that could bring the trust or the NHS into disrepute, nor will any be accepted which promote products or services associated with unhealthy lifestyles (see chart below). 6

7 Category Prohibitions Note Personal injury lawyers Claims management companies Specific no win no fee companies Anti governmental/political organisations Manufacturers of tobacco products Manufacturers of alcoholic products Bookmakers and gambling organisations Pornography/adult industries organisations Funeral directors (except for bereavement literature) Infant formula milk Unrecognised health organisations that carry out plastic surgery. Unestablished products e.g. quick fix diet remedies, unrecognised Types of organisations refused advertising/sponsorship The trust emphasises that advertising or association with any of the listed suppliers, manufacturers or organisations is not permitted, nor with any companies associated with them. Other categories that will require careful consideration before acceptance for sponsorship or advertising includes; public sector organisations, private sector organisations in competition with the trust. In addition, any advertising or sponsorship which expresses a negative view of the NHS will not be accepted. 3. Advertising codes of practice and content All advertising will adhere to the codes of practice issued by the independent regulator, The Advertising Standards Authority (ASA). These state that all advertisements must be: Legal, decent, honest and truthful to the consumer society; Prepared with a sense of responsibility; and In line with the principles of fair competition generally accepted in business. The trust holds an equally open approach to styles of advertising, but advertisers must recognise that NHS organisations cannot permit advertising which contains sexual, adult content or which appears to promote or give undue publicity to illegal or inappropriate behaviour or lifestyles. No advertisements should discriminate or compromise the Equality and Human Rights policy for the trust. 4. Promotion in public areas 4.1 General advertising trust wide 7

8 This could include advertisements on noticeboards, flyers, and adverts on the website or staff intranet. When the trust is approached on general advertising issues, these should be discussed with the Head of Communications, Engagement and Marketing. Payment for advertising will be agreed in line with specific rates. To discuss these rates please contact the Communications and Engagement department on Posters and notices in staff only areas These can be displayed at the discretion of the Head of Communications, Engagement and Marketing and the ward or department manager. All information displayed, however must comply with the rules listed above. Posters and other notices should not be placed on walls or corridors around the building and should only be placed on established notice boards around the trust. Posters and notices will be removed if not displayed in authorised or appropriate areas, or where they may cause damage to trust property. Posters must be removed following the event or when the information is no longer relevant. All trust produced posters must comply with the trust s branding and style guidelines. They can be found at or by contacting the Communications and Engagement Department on There are a number of noticeboards in public areas of the hospital (approximately 52 sites). Some of these noticeboards are designated for use by unions such as Unison, Royal College of Nursing, some are used for staff communications such as benefits or trust news or volunteer news. The Communications and Engagement Department is responsible for checking the hospital s notice boards to ensure the material displayed on them is appropriate in content, presentation and style. It is everyone s responsibility to remove any out of date material that they see in the trust. Advertisements in the form of pop up stands for example, by third party companies may be displayed as part of the trust s advertising and sponsorship packages (see Appendix two for the trust s advertising and sponsorship packages). In this way any income generated can be used to benefit the whole trust. This will be arranged by the Communications and Engagement Department. 4.3 Website advertising Our external website and intranet advertising is populated by an agreement with an external provider - Fendix media who seek advertising on the trusts behalf and implement this. This generates revenue for the trust on a monthly basis. All website and intranet advertising must be carried out in accordance with this agreement. All interested parties in advertising through these digital methods should in the first instance contact the communications and engagement department on Display stands and exhibitions All internal and external third party requests for promotional displays within public areas of the hospitals should be requested via the Head of Communications, Engagement and Marketing. Stands must be booked out through the departmental booking process, collected and returned within the time detailed. Any damage must be reported to the marketing and communications team on The marketing material and display content should be approved to ensure that the subject matter is appropriate and compatible with the trust s core values and objectives. 5. Exceptions 8

9 Any exceptions made to the conditions or terms of this policy will be at the discretion of the Head of Communications and Engagement. 6. Disclaimer Notice Acceptance of any advertising or sponsorship from a third party is not an endorsement or recommendation from the trust for the advertiser s products or services. The trust is not responsible for the quality or reliability of the products or services offered, but it will never knowingly allow sponsorship or advertising which is untrue or fraudulent. All advertising material should include the following disclaimer; Whilst every effort has been made to ensure the accuracy of advertisements, East Cheshire NHS Trust cannot accept liability for any errors or omissions. The trust does not accept responsibility for any claims made by advertisers and their inclusion in this leaflet/publication should not be taken as an endorsement by the trust. 9

10 Equality Analysis (Impact assessment) Please START this assessment BEFORE writing your policy, procedure, proposal, and strategy or service so that you can identify any adverse impacts and include action to mitigate these in your finished policy, procedure, proposal, strategy or service. Use it to help you develop fair and equal services. E.g. If there is an impact on Deaf people, then include in the policy how Deaf people will have equal access. 1. What is being assessed? Details of person responsible for completing the assessment: Name: Fiona Doorey Position: Head of Communications, Engagement and Marketing Team/service: Communications & Engagement State main purpose or aim of the policy, procedure, proposal, strategy or service: (Usually the first paragraph of what you are writing. Also include details of legislation, guidance, regulations etc which have shaped or informed the document) This policy provides guidance to East Cheshire NHS Trust staff and third party organisations regarding allowances for advertising and sponsorship in suitable situations and circumstances. All adverts and sponsorship must comply with relevant regulations and the basic the basic principles of advertising legal, decent, honest and truthful. 2. Consideration of Data and Research To carry out the equality analysis you will need to consider information about the people who use the service and the staff that provide it. Think about the information below how does this apply to your policy, procedure, proposal, strategy or service 2.1 Give details of RELEVANT information available that gives you an understanding of who will be affected by this document Cheshire East (CE) covers East Cheshire CCG. Cheshire West & Chester (CWAC) covers Vale Royal. In 2011, 370,100 people resided in CE and 329,608 people resided in CWAC. Age: East Cheshire and South Cheshire CCG s serve a predominantly older population than the national average, with 19.3% aged over 65 (71,400 people) and 2.6% aged over 85 (9,700 people). Vale Royal CCGs registered population in general has a younger age profile compared to the CWAC average, with 14% aged over 65 (14,561 people) and 2% aged over 85 (2,111 people). Since the 2001 census the number of over 65s has increased by 26% compared with 20% nationally. The number of over 85s has increased by 35% compared with 24% nationally. Race: In 2011, 93.6% of CE residents, and 94.7% of CWAC residents were White British 5.1% of CE residents, and 4.9% of CWAC residents were born outside the UK Poland and India being the most common 3% of CE households have members for whom English is not the main language (11,103 people) and 1.2% of CWAC households have no people for whom English is their main language. Gypsies & travellers estimated 18,600 in England in Gender: In 2011, c. 49% of the population in both CE and CWAC were male and 51% female. For CE, the assumption from national figures is that 20 per 100,000 are likely to be transgender and for CWAC 1,500 transgender people will be living in the CWAC area.

11 Disability: In 2011, 7.9% of the population in CE and 8.7% in CWAC had a long term health problem or disability In CE, there are c.4500 people aged 65+ with dementia, and c.1430 aged 65+ with dementia in CWAC. 1 in 20 people over 65 has a form of dementia Over 10 million (c. 1 in 6) people in the UK have a degree of hearing impairment or deafness. C. 2 million people in the UK have visual impairment, of these around 365,000 are registered as blind or partially sighted. In CE, it is estimated that around 7000 people have learning disabilities and 6500 people in CWAC. Mental health 1 in 4 will have mental health problems at some time in their lives. Sexual Orientation: CE - In 2011, the lesbian, gay, bisexual and transgender (LGBT) population in CE was estimated at18,700, based on assumptions that 5-7% of the population are likely to be lesbian, gay or bisexual and 20 per 100,000 are likely to be transgender (The Lesbian & Gay Foundation). CWAC - In 2011, the LGBT population in CWAC is unknown, but in 2010 there were c. 20,000 LGB people in the area and as many as 1,500 transgender people residing in CWAC. Religion/Belief: The proportion of CE people classing themselves as Christian has fallen from 80.3% in 2001 to 68.9% In 2011 and in CWAC a similar picture from 80.7% to 70.1%, the proportion saying they had no religion doubled in both areas from around 11%-22%. Christian: 68.9% of Cheshire East and 70.1% of Cheshire West & Chester Sikh: 0.07% of Cheshire East and 0.1% of Cheshire West & Chester Buddhist: 0.24% of Cheshire East and 0.2% of Cheshire West & Chester Hindu: 0.36% of Cheshire East and 0.2% of Cheshire West & Chester Jewish: 0.16% of Cheshire East and 0.1% of Cheshire West & Chester Muslim: 0.66% of Cheshire East and 0.5% of Cheshire West & Chester Other: 0.29% of Cheshire East and 0.3% of Cheshire West & Chester None: 22.69%of Cheshire East and 22.0% of Cheshire West & Chester Not stated: 6.66% of Cheshire East and 6.5% of Cheshire West & Chester Carers: In 2011, nearly 11% (40,000) of the population in CE are unpaid carers and just over 11% (37,000) of the population in CWAC. 2.2 Evidence of complaints on grounds of discrimination: (Are there any complaints or concerns raised either from patients or staff (grievance) relating to the policy, procedure, proposal, strategy or service or its effects on different groups?) No 2.3 Does the information gathered from indicate any negative impact as a result of this document? No 3. Assessment of Impact Now that you have looked at the purpose, etc. of the policy, procedure, proposal, strategy or service (part 1) and looked at the data and research you have (part 2), this section asks you to 11

12 assess the impact of the policy, procedure, proposal, strategy or service on each of the strands listed below. RACE: From the evidence available does the policy, procedure, proposal, strategy or service affect, or have the potential to affect, racial groups differently? Yes No Explain your response: All expressions of interest must be treated equally and fairly in line with the Trust s Equality and Human Rights Policy. As long as organisations are not excluded as per the list in this policy, then no one applicant will be favoured over another. GENDER (INCLUDING TRANSGENDER): From the evidence available does the policy, procedure, proposal, strategy or service affect, or have the potential to affect, different gender groups differently? Yes No Explain your response: All expressions of interest must be treated equally and fairly in line with the Trust s Equality and Human Rights Policy. As long as organisations are not excluded as per the list in this policy, then no one applicant will be favoured over another. DISABILITY From the evidence available does the policy, procedure, proposal, strategy or service affect, or have the potential to affect, disabled people differently? Yes No Explain your response: All expressions of interest must be treated equally and fairly in line with the Trust s Equality and Human Rights Policy. As long as organisations are not excluded as per the list in this policy, then no one applicant will be favoured over another. If the advertiser has specific requests due to their audience being disabled, then the Trust will make every effort to support their requests, e.g. providing print in large or bold print, Browse Aloud on website etc. AGE: From the evidence available does the policy, procedure, proposal, strategy or service, affect, or have the potential to affect, age groups differently? Yes No Explain your response: All expressions of interest must be treated equally and fairly in line with the Trust s Equality and Human Rights Policy. As long as organisations are not excluded as per the list in this policy, then no one applicant will be favoured over another. LESBIAN, GAY, BISEXUAL: From the evidence available does the policy, procedure, proposal, strategy or service affect, or have the potential to affect, lesbian, gay or bisexual groups differently? Yes No Explain your response: _All expressions of interest must be treated equally and fairly in line with the Trust s Equality and Human Rights Policy. As long as organisations are not excluded as per the list in this policy, then no one applicant will be favoured over another. RELIGION/BELIEF: From the evidence available does the policy, procedure, proposal, strategy or service affect, or have the potential to affect, religious belief groups differently? Yes No 12

13 Explain your response: All expressions of interest must be treated equally and fairly in line with the Trust s Equality and Human Rights Policy. As long as organisations are not excluded as per the list in this policy, then no one applicant will be favoured over another. CARERS: From the evidence available does the policy, procedure, proposal, strategy or service affect, or have the potential to affect, carers differently? Yes No Explain your response: All expressions of interest must be treated equally and fairly in line with the Trust s Equality and Human Rights Policy. As long as organisations are not excluded as per the list in this policy, then no one applicant will be favoured over another. OTHER: EG Pregnant women, people in civil partnerships, human rights issues. From the evidence available does the policy, procedure, proposal, strategy or service affect, or have the potential to affect any other groups differently? Yes No Explain your response: All expressions of interest must be treated equally and fairly in line with the Trust s Equality and Human Rights Policy. Any issues affecting children such as infant feeding and unhealthy snacks are excluded as per this policy. 4. Safeguarding Assessment - CHILDREN a. Is there a direct or indirect impact upon children? Yes No b. If yes please describe the nature and level of the impact (consideration to be given to all children; children in a specific group or area, or individual children. As well as consideration of impact now or in the future; competing / conflicting impact between different groups of children and young people: c. If no please describe why there is considered to be no impact / significant impact on children All expressions of interest must be treated equally and fairly in line with the Trust s Equality and Human Rights Policy. Any issues affecting children such as infant feeding and unhealthy snacks are excluded as per this policy. 5. Relevant consultation Having identified key groups, how have you consulted with them to find out their views and that the made sure that the policy, procedure, proposal, strategy or service will affect them in the way that you intend? Have you spoken to staff groups, charities, national organisations etc? Staff groups including Corporate Affairs and Governance Managers teams, heads of service lines 1-9 and clinical leads. 6. Date completed: 19/06/14 Review Date:30/06/17 7. Any actions identified: Have you identified any work which you will need to do in the future to ensure that the document has no adverse impact? Action Lead Date to be Achieved 13

14 8. Approval At this point, you should forward the template to the Trust Equality and Diversity Lead Approved by Trust Equality and Diversity Lead: Date: