Op-ed: Reform needed to curb marketing of alcohol, gambling and junk food online

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** Note: This an op-ed from Dr Aimee Brownbill, the Senior Policy and Research Adviser at the Foundation for Alcohol Research and Education (FARE) on why reform is needed to curb marketing of alcohol, gambling and junk food online. FARE has recently released some research indicating that that people seeking to reduce their use are concerned by targeted digital marketing.

We have had an ongoing existing discussion about this topic, but as it has become quite lengthy and stretched across a long period of time, we’ve started this new discussion thread where you can leave a comment below.

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Decision makers are rightfully probing the role of digital platforms like Meta, Twitter, TikTok and Snapchat in Australians’ lives, with multiple inquiries considering the regulations that should apply to multi-national social media companies.



The detrimental impact of digital platforms on public health is largely being overlooked, although with a notable absence of discussion around harmful marketing practices online.

Companies that profit from promoting and selling harmful and unhealthy products like alcohol, gambling and junk food remain free to bombard people with highly targeted advertising. This is facilitated by digital platforms that rely on acquiring vast amounts of data to target people based on a range of personal characteristics, qualities and behaviours.

For many people who are trying to avoid harmful and unhealthy products, this relentless exposure to exploitative marketing can be distressing and can hamper their efforts to reduce or avoid these products to protect their health and wellbeing.

In a survey of 220 people seeking to reduce alcohol, gambling and unhealthy foods, FARE and VicHealth found that 90 percent were concerned about online marketing of these products, while 83 percent felt that seeing this marketing made it harder to abstain.

One participant, Maz, a woman in the 35–44-year-old demographic bracket, described her experience:

“I struggle with alcohol and have struggled with gambling in the past, so when I see [online advertisements], I sometimes get tempted and triggered 
 The constant bombardment with the marketing is wearing down my resilience.”

Better measures are needed to protect people like Maz from online marketing of harmful products. Decision makers need to consider the needs of communities to protect their health and wellbeing when considering regulation of digital platforms.

Currently, this marketing is mostly governed by industry-led, voluntary codes, which are inadequate, ineffective and lack transparency, and do not lead to a meaningful reduction in exposure to harmful marketing.

This is unsurprising, as companies selling harmful and unhealthy products have vested commercial interests and work to maximise profits and shareholder returns.

It is clear from the responses to the FARE/VicHealth survey that measures for reducing the amount of online marketing for harmful and unhealthy products are both wanted and needed in Australia.

Most participants in the survey indicated they have seen online marketing for harmful and unhealthy products within the past month, and that they are concerned about and would like to see less of such marketing.

Half of the participants felt they were personally targeted with online marketing for harmful and unhealthy products.

Evidence supports the concerns of survey participants that marketing of harmful products can interfere with efforts to seek help for addiction and substance use.

Harmful online marketing

Media reports have revealed that alcohol companies bombard people with advertisements after they search for support through groups like Alcoholics Anonymous or rehabilitation services – a likely outcome of the data-driven algorithms digital platforms use to ‘optimise’ advertising revenue.

A review of research with people experiencing alcohol problems suggests that the more a person uses alcohol, the more attentive they are to alcohol cues like marketing, which in turn leads to increased cravings for alcohol.

This creates a harmful cycle in which alcohol marketing becomes more noticeable the more a person craves and uses alcohol – and the more a person notices alcohol marketing, the more they crave alcohol.

Online marketing models fuel this cycle by sending more alcohol advertising to people who use more alcohol.

Reform needed

Reform is urgently needed to reduce the marketing of harmful products online and protect the health and wellbeing of communities.

Decision makers must listen to the concerns of people at risk of harm and take action to increase advertising transparency on digital platforms and restrict the collection and use of data to deliver targeted advertising of these products.



**View the full report from FARE:**
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I believe that Facebook allows you to opt out of targeted advertising, at least for information gleaned from your interaction with other web sites (tracking pixels and the like).

That in no way allows you to opt out of all advertising on social media. It would be silly to expect that, given that a free service has to be paid for somehow. If you are not paying for the product then you are the product.

Indeed. There is almost no transparency across all social media - targeted advertising and all other algorithms.

I would make two suggestions to the Australian government.

  1. Don’t go it alone. We don’t want some Australia-specific hack. Australia needs to partner either with the US or with the EU, and preferably both.
  2. Make sure it really will be effective. We don’t want another “cookies” debacle, where web sites just become uniformly more annoying, without really achieving anything.

There are existing proposals around that would make the “Global Privacy Control” the standard for controlling targeting advertising and the like i.e. the user configures his or her browser to specify that every web request includes an indication that privacy is required. This is legally enforceable in California. Adherence to one global standard would help everybody.

I understand that the real agenda here is to ban or reduce advertising, rather than just to limit targeted advertising.

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To elaborate further on how the example of Global Privacy Control is a step towards the goal presented in this topic, it entrenches two important (to me) principles.

  1. A web server has a legal obligation to respect the wishes of a web client.
  2. It puts the control firmly in the hands of the web client (i.e. in the hands of the individual user). You decide what you see. You don’t decide what I see. The government doesn’t decide what either of us sees.
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A Federal Parliamentary committee has recommended that all gambling advertising at sporting events be banned within 3 years. There is also a recommendation for an Ombudsman to have greater oversight over this issue. The Committee admits that previous approaches have failed.

Some of the recommendations are in response to what was seen as grooming children to prepare them to be future gamblers. My opinion was and is that the proposed changes do not go far enough, most of the banning only applies to online ads and does not stop all forms of advertising. I think it should be complete but my view is perhaps an extreme example of what outcomes should be expected.

Some people are asking why it will take that long, I suspect and it has been admitted that it will allow some contracts to run out and give time for alternative monetary support to be found to pay for what the current advertising pays for.

An ABC article on the matter

The report can be downloaded and read at the following link

If you would like to read the recommendations only then see

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Some more from the enquiry into online gaming.

The inquiry has heard evidence that some companies will reduce maximum bets or block access entirely when gamblers are on a successful run.

SportsBet CEO Barni Evans said customers are blocked only in very narrow cases.

“If we believe that they’re acting with information that the rest of the market doesn’t have, and if their behaviour is distorting the market, which means that other customers’ experience is affected, then we will take action,” Mr Evans said.

In a terse to-and-fro, Mr Evans twice repeated a similar response, despite Ms Murphy’s efforts to extract more information from him. Ms Murphy concluded by saying she would accept Mr Evans’s evidence as a “yes, you stop people who are consistently winning from betting”.

“That’s your prerogative,” Mr Evans replied.

An interesting response from SportsBet. Firstly that they block successful gamblers but they refuse to admit it. Seondly, they admit that the only way they can think of that somebody can consistently win is if they have information the market doesn’t have and lastly they consider that to be unacceptable, ie cheating.

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They want you to pay, they don’t want you to be paid (well to be paid more than you paid to them). If people win too much then they don’t make the profit they want and they only make profit when people lose more money than they win. So it could be asked who is cheating whom???

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Yes, I suspect that is the reason too. That is only reasonable. If they just voided the contracts tomorrow then that would be a massive sovereign risk and we are probably talking about contracts that run into the hundreds of millions of dollars.

If you’ve read everything that I’ve posted in this forum then you would probably realise that I don’t agree with the government. As gambling is essentially a financial transaction, I believe it should be tackled via the finance sector, so that the impacts can be limited to those who are gambling and losing a lot.

Yes, not very transparent. I would be wondering: is blocking successful gamblers a purely algorithmic thing or is there a human in the loop?

I think they could have been pushed much harder on this point.

It’s a fine line but aren’t they correct about that? If we were talking about share trading then this would be outright illegal. Right?

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But they don’t know that someone is cheating. If someone is very knowledgeable, is able to account for most of the variables, statistically they may be able to win far more often than they lose, then because they are successful they get banned. If a loser though, then the system offers them incentives/encouragement/enticement to continue to gamble and lose even more. The winner is banned and the loser is encouraged to lose even more, that is perhaps the greatest cheat of all. This was highlighted as the case in the Inquiry, those who lost were encouraged to continue, if someone was more consistent as a winner (particularly a large winner) they were banned. Again my opinion only, from what has been said in the Inquiry is that the odds of getting more from gambling than what was bet have been so far skewed by the gambling businesses that they believe to consistently win against them must involve cheating.

To call all winners or indeed any winner cheats because they more often consistently beat the odds and doing so without solid evidence of doing so without right of trial is perhaps a greater injustice. If they have proof (beyond just successful bets) then present it in a Court as that would be fraud. I think and it is entirely an opinion that the practice is based purely on profit driven motives.

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That’s true but that isn’t my point. My point was specifically in response to the text that I quoted i.e. is it unacceptable / cheating to be in possession of information that is not generally available to the “market”?

As you say, proving it is a whole different problem. Most of your comments, including that quoted above, could apply equally to insider trading.

It depends on the type of gambling. If you are talking about the pokies then there are “no” winners and, yes, losers are encouraged to keep gambling and keep losing.

If you are talking about sports betting then punters as a whole always lose and the company always wins - and they win regardless of which punters win, which punters lose, and whether it’s always the same punters who win. That’s because the odds (payouts) are calculated based on the bets placed. The company can’t lose. (This is specifically referring to a simple win/lose bet. There are now so many combination bets that I don’t know whether that remains absolutely true but for sure the company will try to make it true.) So the incentive for the company is just to make sure that punters keep betting. As long as punters are betting, the company is making money.

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insider trading is against the law.

A random hit. It happens.

https://asic.gov.au/about-asic/news-centre/find-a-media-release/2022-releases/22-149mr-caloundra-man-sentenced-for-insider-trading/

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This is my my opinion only

I don’t think they (the gambling businesses) just want the milk, they want the cream off the top as well. Like all businesses they want to maximise and indeed are often required to get the biggest profit possible at the least possible cost. If I bet $1 and the odds are 1:1 then I get both my bet and the $1 win back i.e. $2, the company loses against my bet. They get no dollar benefit from my bet, it is a cost to their business.

A bookie often will offset bets to another bookie similar to insurance of insurance against an event. I am pretty sure that these large online businesses may have a similar insurance policy but even if they don’t, they set odds such that they expect and are almost 100% guaranteed that they will pay out far less than they take in any matter they offer odds on. They would have actuaries pouring over the figures to ensure they make the greatest profit possible from any event, any variation to that maximum from what is expected would to their minds involve cheating as they have made it almost impossible to have any other outcome.

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Yes, but that isn’t how it actually works. The company can’t lose. They are offsetting your bet against someone else’s bet, specifically someone who bets the opposite result.

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It depends on the information and how it was obtained. There are situations when by considerable hard work people accumulate public information and distil it to give them a better understanding of past behaviour. Some believe this is a way to improve the odds when they bet, that past behaviour to some extent predicts future behaviour, they may be right, at least to some extent.

There is also the question of how SportsBet make their determination. If they actually have direct knowledge that the bets were laid based on improper information that is one thing, if they just ban anybody who is doing well without such direct corroboration that is another.

The constant position of big gambling providers is that their business is a game of chance. They know and admit that they set the odds to be in their favour. That ensures that in the long run most players will be losers and they will be the winners, the odds of this happening in aggregate are so huge as to almost be a certainty.

Interestingly there is a contrary possibility that given enough bets, even if each one has a loss more probable than win, that in sum it is possible to win sometimes.

Say we have a fair coin toss where the chance of a win is 50% on each throw. We toss ten times and then count the result. In the long run in aggregate there will be a distribution of outcomes around the middle, ie 5 out of 10 correct. It is also likely that a few will have a run in their favour, you can (given enough tosses) win ten such bets in a row without cheating.

In the SportsBet case the chance is not centred about 50% but in their favour. You are constantly making bets with less than 50 % chance of winning but the run of luck is still possible as it is with the fair bet - albeit less likely.

If this is the basis of the SportsBet behaviour of not allowing winners to keep winning they are certainly cheating as they are diverging from their stated desire to run a game of chance.

The reports of the enquiry do not say if the question was asked how the decision to block some players was determined by SportBet.

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Could I politely suggest that this is getting off topic.

Surely the issue is about advertising normalizing an association between something that is for some, harmful, and enjoyment. Clearly the case with tobacco. Not so clear with alcohol. But with sports it seems that gambling is freely promoted as part of the experience of watching. And not just you against the bookie. But drag your mates into as well as a group loss.

Insideous stuff.

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The reported evidentiary stance is that losers are encouraged to continue, consistently winning is however dealt with by first slowing down the betting person’s ability to bet and as a final measure banning them. In some cases bets are limited for a number of other reasons.

While I’m not privy to all that evidence, it has been reported on, not only by the ABC either in case it is thought it might be mis-reporting.

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Possibly. If you accept that the same reasons are behind the way that organised gambling behaves operating offline, operating online and advertising are all the same and that the negative outcomes for individuals and society are also the same for those activities - maybe not.

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Yes. The original post refers to online advertising, which might be more difficult to regulate compared to more traditional forms of marketing.

I don’t take a lot of notice of the said form of advertising. For those who do, what do you see as harmful and what changes would you like to see?

The title mentions alcohol, gambling and junk food. However, recent posts relate to gambling only. To those who have posted, do you have similar concerns relating to alcohol and junk food advertising?

I would be in support if advertising for each of the three product groups was further restricted or banned, as long as the decision is based on sound facts. General discussions seemed to be skewed towards restriction of gambling ads. My view is that the order of most harm from advertising, junk food is worst, then alcohol and gambling coming in third.

My opinion is formed after considering the following:

  1. How accessible each product is, particularly to children.
  2. Whether parents and/or others are more likely to encourage or discourage the use of the product.
  3. Whether the feedback on the harmful effects is immediate or in the very distant future.

If you ask me to rate the advertising of those product in terms of the entertainment value I would place gambling ads a very distant last.

To keep the off-topic trend going, there are some uniformed comments about how a bookie might operate. Whilst the odds are theoretically in their favour, on any given event the bookie can lose if one or more possible outcomes eventuates and win if one of the remaining outcomes eventuates. This may be due to them backing their judgment or simply because the public has chosen to bet more heavily on certain possible outcomes.

Regarding comparisons to insider trading, the different sporting codes may have rules dictating who can or cannot bet, what information needs to be made public and how people need to behave. Outside of this and general laws about fraud etc., anything is fair game. For example, if a trainer knows that their horse runs well on a muddy track there is no requirement to publicly disclose this fact.

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I think your three points sum it up. Access is key, despite protestations to the contrary vendors of junk food, booze and gambling do want to expand access as much as possible and to have their product normalised so that they are accepted as widely as possible, including inoculating children with the desire.

Such vendors may say publicly that sweet/fatty/salty food ought to be an occasional treat, that we ought to drink responsibly and they include obligatory warnings about gambling (as briefly as possible) in their ads but in reality they want all those things in every house as often as possible.

The foray into alcoholic lolly water by the booze industry mainly aimed at young females, including those not old enough to buy their own, is a great example. The food and betting industries have their own shamefully targeted products and ads to sell them.

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Reality may be that those who share similar values to Choice or the common views in this Community are more resistant to most forms of marketing.

ABC TV’s Gruen program from Wed 28th June pulled the notion that gambling advertising was harmless apart.

It’s a business sector that spends $300M annually just on advertising. It supports large media organisations, is integrated into the income streams of large sporting organisations, and seeks to normalise gambling as a social and rewarding experience.

The alternative view point is it creates unhealthy outcomes that impact directly and indirectly on many lives as a result of the addiction it encourages. One comment suggested more than 500,000 young Australians (school age) now gamble daily through on line betting.

Every dollar spent gambling is one dollar not put into more productive outcomes for the community. Nearly $2500 annually for every adult Australian. True, Government takes approx 10% in taxes. An addiction of a different kind.

It’s a choice to gamble, wager or punt depending on how honest one is with the facts. No advertising required. It’s now left for those elected.

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Not on the version of the show that I watched. The presenters on that show would have trouble pulling apart a pre-split hamburger bun.

Almost. The statement was along the lines of just under 500,000 kids under the age of 16 are gambling online every day. This was a statement made by an advertising person with something to sell. My view is that, if the reference related to Australia, you would need to have a very broad definition of gambling and/or the term “just under” for this to be anywhere near reality.

Hardly. Somewhere around 90% of money gambled is returned to the gamblers. The remaining amount is shared between governments and the business operators, employing people and providing public facilities.

That is an amount relating to turnover. The actual average loss per adult would probably equate to the cost of a going out for a smashed avo on toast once every two or three weeks (less frequently if you wash it down with a yuppy coffee).

One issue relevant to this topic, raised in the Gruen segment, is the presence of gambling advertisement in largely unregulated aps such as tik tok.