So far this year, the Advertising Standards Authority has received more than 300 complaints about online advertising. Which, given the nature of the medium, is an astounding figure. Have these people nothing better to do? What can they find to complain about in banner advertising?
With your average letterbox-shaped bit of typography garnished with some sort of (often modest) graphic, there's surely not much scope to offend even the most sensitive of sensibilities. We don't need the ASA getting involved, do we?
The ASA obviously thinks we do. And this issue is not as simple as you would think. The contentious area here isn't taste and decency - the majority of complaints are from consumers who feel they have been misled or presented with claims that can't be substantiated.
Only 25 per cent are from people who have been offended. That, as the ASA points out, reflects the situation in the offline world, where advertisers' claims are the biggest source of complaints too.
It's not too hard to extend this argument. As the line blurs between many aspects of online and offline advertising, there's a case for the same codes of practice applying across the board.
Which is why the ASA last week moved to clarify what its existing codes cover when it comes to the online sector - it has also launched a 'kitemark' scheme that it hopes will be of interest to advertisers using banner, e-mail marketing and promotions.
Called admark, the ASA initiative is an opt-in scheme for online advertisers and publishers and it covers everything from banner ads to sponsorships and permission-based marketing e-mails. Those choosing to display an icon within online ads will, the ASA believes, enhance their reputation and ensure that they have the confidence of consumers.
The ASA's director-general, Christopher Graham, says: 'This scheme will be good for consumers. It sends a message that admark members commit themselves to producing, hosting or distributing online advertising that is legal, decent, honest and truthful.'
Founder members include 24/7 Media, the Royal Mail and Engage, an interactive marketing company. It also has the support of the Internet Advertising Bureau. Barbara Newman, the chair of the IAB's e-commerce working group, says: 'It's not revolutionary and most advertisers are actually doing what the recommendations suggest already, but I think this move is significant in helping to extend self-regulation.'
Should the ASA initiatives be welcomed by the industry? After all, it has prided itself on its frontier status. Many are dubious about the scheme, although there is widespread recognition that there have been problems with overclaiming in banner ads. This, they say, is understandable - the fact that you can say less in a banner ad has led to some lax attitudes.
One industry source comments: 'There's not a lot you can do with a banner so you have to be succinct if you're going to attract attention in a few words. But when you take a wide perspective of the internet, you would have to say that all the adverse publicity has been about e-commerce problems and privacy. In that context, advertising has not been a problem.'
David Stubley, the managing director of Outrider, admits he is yet to be convinced about the scheme. He says: 'You could argue that the ASA is an old economy outfit looking for a role in this brave new world. I think there's a real danger in applying old economy thinking. Look at the viral campaign for Breathe where you click to inflate a blow-up doll. It was successful, but what would the ASA have said about it?'
Stubley is not alone in believing that the old rules may not apply. One agency observer says: 'It comes back to that old question about how you regulate the internet. It's just not possible, is it? I can see why some people may welcome this because they believe it will keep sharks out, but I think they might come to realise they've painted themselves into a corner.'
Some of the sceptics are willing to concede that there might be a role for the ASA. But not, they insist, in putting little logos everywhere. Stubley concludes: 'If there is a role for the ASA, it's perhaps in copy clearance. People could post copy on a site and cleared copy could receive a digital signature. The use of logos is not the way forward.
'Average response rates to banner are typically less than 1 per cent, so it's hard enough to get people to respond without slapping kitemarks on them. Creatively, you have so little to work with in the first place.'