Advertising Standards Authority (ASA)
Do homeopaths’ claims that trials are too expensive and that they can’t afford them hold water?
Science is simply a systematic way for carefully and thoroughly observing nature and using consistent logic to evaluate results. Which part of that exactly do you disagree with?
— Dr Steven Novella
But homeopaths have a problem: all advertising in the UK has to comply with the Advertising Standards Authority’s CAP Code and this rightly demands a high standard of evidence for any claim, regardless of whether it’s about how clean a soap powder makes your whites, how efficient double-glazed windows are or how much a skin cream reduces the appearance of wrinkles. So it is with homeopathy: high quality evidence is required.
There have been several ASA adjudications recently against homeopaths (eg Steve Scrutton), homeopath trade bodies (eg the Society of Homeopaths — and you must watch this superb demolition of their ‘evidence’) and homeopath advocacy groups (eg H:MC21) and these have shown the paucity and extreme poor quality of homeopathic research.
But there doesn’t seem to be that much new research being conducted that might allow claims to be made in the future. Instead, there are moves to try to persuade the ASA to lower their standards in the hope their evidence will meet this easier threshold, campaigns to oppose the ASA, petitions raised to force the ASA to change its ways, with frequent shouts of ‘Censorship!’, ‘Bias!’, ‘Freedom of speech!’ and double standards.
There are even moves afoot to ‘re-categorise’ the literature on homeopathy. This is in the early stages and will probably take a few more years to complete, but there will be no prizes for guessing what the conclusions are likely to be — a comparison with the farce surrounding the Swiss report on homeopathy is inevitable.
Patient success stories Anecdotes
But homeopaths insist there is ample proof that homeopathy works already, and are keen to point out the large numbers using homeopathy as if that was an indication of efficacy. Ah, that old canard — evidence in the form of anecdotes — doesn’t wash with anyone even vaguely aware of the problems of bias and with an interest in getting to the truth of the matter; and certainly not up to the ASA’s standards. Many websites of homeopaths laud their customer testimonials and there are several websites that actively gather anecdotes (or ‘patient success stories’ as they sometimes like to call them) such as Homeopathy Worked for Me, Patient Testimonials and a relatively new one, Making Cases Count. And of course there are their celebrity endorsements; where would homeopaths be without their celebrity endorsements?
A number of anecdotes may indicate that something is worth looking at in more detail, but they are no indication of the efficacy of homeopathy and they certainly don’t change the state of the robust, independent evidence for homeopathy — or rather, the lack of it.
Many homeopaths rubbish science of course, dismissing it as reductionist and entirely unsuitable as a means of testing their precious homeopathy. But they fundamentally misunderstand science. As Dr Steven Novella puts it:
What do you think science is? There’s nothing magical about science. It is simply a systematic way for carefully and thoroughly observing nature and using consistent logic to evaluate results. Which part of that exactly do you disagree with? Do you disagree with being thorough? Using careful observation? Being systematic? Or using consistent logic?
Yet homeopaths crave scientific respectability — they laud (erroneously), for example, the neutral Swiss Government for their highly positive homeopathy HTA and just about every half-baked study they can twist to make it support their favourite hobby-horse. They know that they will not make the progress they believe they deserve unless they can, finally, provide that good scientific evidence they just know is waiting to be found. As I’ve mentioned, it was this lack of good evidence that lost both the Society of Homeopaths and the homeopathy advocacy organisation, Homeopathy: medicine for the 21st Century (H:MC21) their Advertising Standards Authority adjudications for claims they had made in adverts. Not just on a few minor points here and there, but a complete and utter demolition of their homeopathic claims.
There are even some university academics who spend their time researching homeopathy, such as homeopath Dr Clare Relton, Senior Research Fellow at the University of Sheffield and homeopath Dr Elizabeth Thompson, Consultant Homeopathic Physician [sic] and Honorary Senior Lecturer in Palliative Medicine at University Hospitals Bristol. There are many others as well who see themselves as legitimately researching their sugar pills.
There are even organisations whose sole purpose is to improve research into homeopathy. Take the Homeopathy Research Institute (HRI):
The Homeopathy Research Institute is an innovative international charity created to address the need for high quality scientific research in homeopathy. We use our resources and expertise to foster new projects and to improve the quality of research being carried out in the field.
Anyway, the HRI heralded that their conference in Barcelona this year would be, “A significant step forward for homeopathy research“. A critical thinker might be considerably less than underwhelmed by what actually happened.
But at least they are trying to do some research; and scientific to boot. Indeed, they have seven research projects running at the moment:
- Case series of 20 children diagnosed with ADHD treated with homeopathy for a year
- Depression – What is the role of treatment by homeopaths?
- Irritable Bowel Syndrome (IBS) randomised controlled trial
- Online database of homeopathic scientific literature
- Physico-chemical properties of homeopathic dilutions
- Physics of homeopathic dilutions
- Theories of homeopathic dilutions
Well, by ‘running’, I mean that they are trying to raise the money to fund them.
This list certainly covers a lot of ground; most don’t require any research to answer, though…
But the one on depression says it’s simply part of a PhD:
This project will evaluate the acceptability and the comparative effectiveness of adjunctive treatment provided by homeopaths for patients with self-reported depression, in addition to usual care.
So it’s guaranteed to give positive results even before it’s started!
But how much does this research cost and how on earth could they raise the money?
In conventional medicine, pharmaceutical companies have the advantage of having funds for research. Alternative medicine lacks that.
It seems like homeopaths are so adept at coming up with excuses, anyone would think they can anticipate the outcomes…
But, other than tapping the likes of leading homeopathy manufacturer Boiron — with its market capitalisation value of just under 1 billion Euros — how on earth can they afford this very necessary research? Until they have positive results from robust, high quality trials, they will not be able to make the claims they might like to in their advertising, so the onus is definitely on them to do whatever’s required to advertise their businesses honestly.
|Depression: What is the role of treatment by homeopaths?|
|Homeopathy Research Database|
|IBS Trial: Phase 2 Fundraising Appeal|
|Irritable Bowel Syndrome (IBS) randomised controlled trial|
|Physico-chemical properties of homeopathic dilutions|
|A new quantum theory to explain homeopathy|
|Physics of homeopathic dilutions|
|Theories of homeopathic dilutions|
|ADHD case series|
Of course, these are just the target amounts they want to raise from donations and they could have additional funding secured from elsewhere, but note that four of them have offline donations already.
This could also answer the question about how much a homeopathic trial costs and it won’t go unnoticed that the Q-word rears its ugly head.
Positive by design
Their two IBS projects (IBS Trial: Phase 2 Fundraising Appeal and Irritable Bowel Syndrome (IBS) randomised controlled trial) are raising funds from two different websites: one with a target of £15,000 and the other of £10,000. However, in the past 12 months, excluding a one-off online donation of £10,000, they have raised a grand total of just £1,490 from the public.
But maybe these are one and the same trial? They certainly appear to be — and it is this trial that is discussed by Prof Edzard Ernst: Homeopathy for IBS? When will we stop wasting resources on such useless pseudo-research?
We are again dealing with an A+B versus B design, on top of it without patient- or therapist-blinding. This type of analysis cannot ever produce a negative result, even if the experimental treatment is a pure placebo: placebo + usual care is always more than usual care alone. IBS-patients will certainly experience benefit from having the homeopaths’ time, empathy and compassion – never mind the remedies they get from them. And for the secondary analyses, things do not seem to be much more rigorous either.
Obviously, I have not seen the data (they have not yet been published) but I think I can nevertheless predict the conclusions of the primary analysis of this trial; they will read something like this: HOMEOPATHY PROVED TO BE SIGNIFICANTLY MORE EFFECTIVE THAN USUAL CARE. I have asked the question before and I do it again: when does this sort of ‘research’ cross the line into the realm of scientific misconduct?
That protocol document says:
This trial has received NHS approval and results are expected in 2013.
It received Barnsley Hospital internal approval on 14 December 2009, ethics committee approval on 9 December 2010, and the protocol paper was published a further two years later, on 6 November 2012.
So, having published the protocol, and with the Current Controlled Trials entry saying it is completed, with an anticipated end date of 31 December 2012, what is the current status of this research? I don’t know. Perhaps they still need money to analyse the results and write up the paper?
Touting for money
Vital IBS trial needs your help
Funding needed: £15,000 Total raised so far: £1,900
Then in March 2103, they said:
IBS trial fundraising appeal – update
On behalf of the researchers at Barnsley Hospital involved in the Homeopathy for Irritable Bowel Syndrome trial (HIBS), HRI would like to thank everyone who donated to our fundraising appeal last November in support of this project. There was a hugely positive response to our appeal, with many warm messages of support as well as donations which totalled just over £2,000. In these hard times, it was a fantastic response from individuals. Click here to find out exactly how these funds are going to be put to use.
“There was a hugely positive response to our appeal”? It doesn’t matter what the true figure is, whether it’s £1,490, £1,900 or even £2,000, it falls dramatically short of the £15,000 they said they needed. I think they mean ‘a truly homeopathic response to our appeal’.
But they go on to give the bad news:
However, shortly after these funds were raised, changes at Barnsley Hospital meant that it would no longer be possible to carry out a second phase of the trial (involving recruitement [sic] of more patients) as intended. Instead, the aim now is to publish the existing HIBS trial results which, in the opinion of Prof Kate Thomas (an expert in Health Services Research) form a “robust pragmatic pilot study”.
After much discussion with stakeholders and those who made donations, the money raised by HRI will be used to provide seed funding for Jackie Raw RSHom (homeopath and HIBS project manager) to carry out a one-year prospective service evaluation of her work providing individualised homeopathic treatment for patients with IBS at Barnsley Hosp NHS Foundation Trust. Jackie would be aiming to treat ~ 30 patients and the total cost of the project has been estimated at £5,000.
It’s just not clear to me what’s going on but I sincerely hope they weren’t raising money for a project that has already been completed!
Bringing home the bacon
But after failing to raise very much funding from their supporters, the HRI now want the taxpayer to pay for research! In their submission to the House of Commons Science and Technology Committee inquiry into antimicrobial resistance (AMR), they want the Department of Health to consider using magic sugar pills to combat the very real threat of resistant bacteria, viruses, etc.
Without a hint of irony, they ask:
1.3 HRI recommends that the Department of Health conducts research to determine definitively whether homeopathy is efficacious for [ear infections in children] (we suggest a multi-centred randomised placebo-controlled comparative trial).
1.4 HRI recommends that Defra conducts research to determine definitively whether the homeopathic medicine Coli 30K is efficacious for reducing the incidence of E.coli bacteria in neonatal piglets (we suggest a multi-centred observer blinded, randomised placebo-controlled trial).
And of course:
1.10 HRI would welcome the opportunity to assist the Department of Health and Defra in investigating the potential for homeopathy to play a role in tackling AMR.
I’m sure they would.
Of course, the elephant in the room is the fact that, even though these fund-raising campaigns have been running for over a year, they have only managed to scrape together a measly 20 online donations. They do seem to have an anonymous offline benefactor, but even taking all donations into account, all they have managed to muster is 20% of their total.
So it seems that homeopaths and their customers aren’t too willing to pay for research.
Maybe we’re expecting too much here. Maybe the money just isn’t there in these straitened, austere times?
But maybe we also need some alternative thinking here: rather than wringing hands and saying it can’t be done, how much could be raised by practitioners with a small levy on each appointment? That sounds like an easy way of raising funding: from the very people who desperately need to keep on the right side of the rules for their advertising and who will benefit most from being backed by good scientific evidence.
After all, there are several thousand homeopaths plying their trade in the UK. The FindAHomeopath website boasts 3,032 who are members of either the Society of Homeopaths, the Alliance of Registered Homeopaths or the Homeopathic Medical Association. (They also claim to include members of the Faculty of Homeopathy/British Homeopathic Association, but none are listed.)
So, what could be raised if a small levy was charged on each appointment?
You can imagine the objections:
- We can’t afford it!
- Our customers can’t afford it!
- It’ll never work!
- It’ll be too difficult!
Well, let’s see. Let’s find out how they could raise the funds for dozens of trials — let’s play with some numbers with a handy calculator and see what drops out.
- the number of practitioners working in the therapy
- the average number of appointments per day
- the average number of days per week worked
- the average number of weeks worked in a year
- the average cost of an appointment
- the percentage levy to be used to generate funds for research
The calculator will show the number of appointments per practitioner per year, the practitioner’s income per year, the total number of appointments per year, the levy per appointment and the total raised per year.
So, using these default values of 3,000 practitioners, doing just four appointments a day, four days a week, 40 weeks of the year, asking for just 1% (50p) more from each customer — or donating that small amount from profits — means that they would raise a research fund of just under £1 million — each and every year.
This 50p would cover the HRI’s puny total of £196,000 nearly five-times over; 10p would still just about cover it.
Even if the default numbers I’ve used are optimistic (perhaps lots of them just work part-time), it’s very easy to see how they could raise a significant amount of money very easily, with just a little effort.
Try some figures for yourself.
Of course, these simple calculations can be applied to any therapy that is lacking in positive research such as reflexology, reiki, Bowen therapy, craniosacral therapy or any similar pseudo scientific nonsense.
If any practitioners — or their trade bodies — really wanted to try to come up with the good evidence they’re probably convinced exists, then what’s stopping them? After all, if they were able to produce good evidence, they might be able to convince the ASA to accept their advertising claims.
However, if they don’t even try to get good trials done, they will forever pay the price in their advertising.
What does the two-decade-old ‘endorsement’ by The Times really say?
Any reader not aware of the current fuss and bother over the What Doctors Don’t Tell You magazine can find a comprehensive list of blog posts, etc curated by Josephine Jones: WDDTY: My Master List.
In a recent spat — after The Times published an article by Tom Whipple (Call to ban magazine for scaremongering) — WDDTY posted a scan of part of a 1989 Times article that appeared to praise their original (online subscription) publication of the same name, saying it was “A voice in the silence”.
WDDTY use this same endorsement 24 years later on their main website, the WDDTY subscription website for their latest glossy, supermarket edition (although they get the quote mixed up with others) and in the glossy magazine itself.
Despite calls for them to publish the complete article, its editor, Lynne McTaggart, has not obliged, so I will.
Note the charming cartoon of WDDTY being used to beat up a doctor.
I’ll leave you to ponder the full article, but here are some quotes:
[WDDTY] promises to reveal all those irritating little things the GP has been keeping to himself, such as the potential side-effects of drugs.
McTaggart: “[WDDTY] will wage war on “doctor-induced disease” — illnesses triggered by prescribed drugs.”
McTaggart: “We are not gunning for doctors and we are not an alternative medicine journal. We feel that the cure should be worth the side-effects, and that people have a right to as much knowledge as possible so they can make an informed decision.”
[McTaggart] feels her magazine is needed because people may be willing to lose their hair to achieve remission from cancer — but not to cure a headache.
McTaggart: “We will be exposing alternative therapists, too”
McTaggart: “[doctors are] being taught that vitamins and diet are not important and there is a pill for every ill.”
McTaggart: “It is impossible for the average doctor, unless he has a computer, to understand how all these drugs can react and overlap. They can only trust the regulatory bodies.”
McTaggart: “If we ever make any money out of this I’d like to use it as a lobbying body in Britain.”
McTaggart says her journal will accept no advertising — “we have to remain pure”
WDDTY is not without promotional gimmicks. Subscribers will receive a free copy of the What Doctors Don’t Tell You guide to the side effects of drugs — a “ready reference guide” to fit into a Filofax [a kind of portable, tree-based information retrieval system — Zeno]
One of the future stories puffed in the sample issue is “New tests for candida sufferers”, together with “Alternative cancer therapies: what’s really working?”, “Why you should think twice about immunizing your child” and “Why to avoid ultrasound tests if you’re pregnant”
The sample [magazine] leads on a report entitled “The breakthrough that backfired” and accuses doctors of over-using antibiotics “once reserved for life-threatening illnesses” because of an “unholy alliance” between doctor and patient that all illnesses can be treated with drugs.
Antibiotics, the article goes on to say, can weaken the immune system, leaving the body open to candida, “gastro-intestinal or hormonal disorders, severe allergies, psoriasis or even multiple schlerosis [sic]“
The article goes on to quote Caroline Richmond, founder of the Council Against Health Fraud (now known as HealthWatch), dismissing the publication as a “scaremongering crusade” and saying “my quackbusting detector is working overtime at the sound of this.”
She also questioned WDDTY’s ‘volunteer advisory panel’ of “top medics”, asking why there were so few real doctors. Blogger Josephine Jones has recently had to ask a very similar question: WDDTY: The Editorial Panel. The answer Josephine gives may not be all that surprising.
McTaggart was asked if she was “worried about protests from the multi-billion pound drug industry which should find the new publication a bitter pill to swallow?”, apparently. Her answer:
My first book was on baby stealing in the United States, attacking six powerful lawyers. They didn’t like what I had written but they had to admit it was fair. Accuracy is a powerful weapon
Has What Doctors Don’t Tell You lived up to this billing? Has it been successful? Have they exposed alternative therapists? Has its attitude to doctors, conventional treatments and evidence changed in the intervening two decades? Have they been a voice in the silence?
I’ll leave that for you to decide.
There are many nutritional therapists who will give responsible, evidence and science-based advice. What is OfQuack doing to ensure their nutritional therapists don’t mislead the public? Their new ‘therapy descriptor’ needs careful analysis.
I blogged a few days ago about the investigation by the consumers’ organisation Which? that revealed nutritional therapists giving dangerous and misleading advice — most of those investigated were members of the British Association for Applied Nutrition and Nutritional Therapy (BANT).
In 2009, BANT passed any regulatory responsibilities they had on to OfQuack, aka the Complementary and Natural Healthcare Council, and they have just published a revised ‘therapy descriptor’ for nutritional therapy.
This version has been revised — and the previous one removed — after discussion with the Advertising Standards Authority. Presumably this new one is accepted as being compliant with the CAP Code — the Code all advertisers have to abide by in their advertising, whether in the media or on their own websites.
Many websites of homeopaths are changing. Some as a direct result of being contacted by the Advertising Standards Authority (ASA) and some, no doubt, because, now they are aware of the ASA’s rules, want to be responsible and abide by them.
I’ve been watching several websites change over recent months: some delete a few words here and there; some have had to make substantial changes; and some have yet to make the necessary changes.
One of the websites I’ve been watching is the one belonging to the Society of Homeopaths.
Their home page had this:
Homeopathy is an evidence-based medicine which offers holistic, individual and integrated treatment with highly diluted substances with the aim of triggering the body’s natural system of healing.
A few days ago, they changed it to say:
Homeopathy is a form of holistic medicine in which treatment is tailored to the individual.
Have they finally realised that it’s not ‘an evidence-based medicine’; that there is no robust scientific evidence (ie the kind required by the ASA to protect the public from misleading claims) that homeopathic sugar pills have any effect over placebo?
I doubt it, but sooner or later homeopaths have to realise that they have to abide by the same rules as every other advertiser: if you make a claim, you must have robust evidence to substantiate it.
If a double-glazing seller claims his windows use an alternative glass that works far better than ‘conventional’ glass, then we would — rightly — expect him to be able to back up that with good evidence. There cannot be one standard for, say, double-glazing sellers and different, lower standard, for homeopaths.
And so with the homeopaths or any other advertiser of alternative therapies. Indeed, there could be a case made for requiring an even higher standard of evidence for claims about healthcare made to an unsuspecting public.
It’s bad enough when homeopaths take good money from people, claiming they can cure their colds or clear up their eczema with sugar pills. It’s another thing entirely to claim to prevent or treat serious diseases with identical sugar pills.
But this is precisely what the BBC’s Newsnight programme discovered homeopaths were doing. Broadcast in January, Pallab Ghosh exposed the disgraceful behaviour of a north London homeopath and a homeopathic ‘pharmacy’ selling sugar pills as a malaria preventative.
Watch the whole sorry exposure, even if you’ve watched it before:
As Dr Simon Singh said on the programme:
Choice is fine as long as it’s based on accurate information. And the information that’s being given out by pharmacists, by celebrities endorsing homeopathy, by the NHS offering homeopathy — the implication here that homeopathy must be effective otherwise people wouldn’t sell it, profit from it or offer it in the high street. And I am utterly shocked that we have a woman here [Zofia Dymitr, Chairwoman of the Society of Homeopaths] saying that she’s not going to forbid her members from offering homeopathic prevention of malaria to the general public. There are people coming back from tropical countries with multiple organ failure having used homeopathy and yet this woman is not prepared to stop it.
I was here four years ago when Newsnight did your last investigation and BBC Scotland have done an investigation and BBC South West have done an investigation. The BBC are the only people regulating homeopathy at the moment, because the Society itself seems to be oblivious to its responsibility.
Is ‘homeopathic’ an accurate description of self-regulation?
The Advertising Standards Authority (ASA) are paragons of efficiency and professionalism. They may well have a lot to deal with at the moment, but that does not stop them investigating complaints thoroughly and responsibly. They take the business of regulation seriously and have a well-deserved reputation for being fair, independent and impartial.
That’s how a regulator should conduct its business if they are to be seen as thorough and effective, particularly where there is a need to protect the public from those who would prey on their trust, ignorance or vulnerability.
The ASA have an advantage over the trade bodies that parade their Code of Ethics as banners of respectability to entice the public to believe their members are being properly regulated. The ASA operate at arms length from those who fund them: those who decide on whether an advert is legal, decent, honest and truthful treat all complaints equally, regardless of who the advertiser is or who the complainant is.
It’s a pity the same cannot be said for the ‘regulators’ of purveyors of ‘alternative’ therapies.
There have been a few emails back and forth — and it would be best to read the conversation before continuing — but I felt I needed to add my tuppence-worth:
I’ve been following your conversation with Simon Perry with interest and I’d like to respond to some of the points you made.
As a regulator you cannot honestly expect us to support a position as stated by you to the effect that ‘………..Genuine, honest training on reflexology must cover the simple truth that reflexology is not known to be effective for any condition.’
This is your opinion and in our view, is unsupportable as a statement.
Simon didn’t express an opinion and it’s entirely supportable. The scientific evidence on reflexology is clear: it is a nice foot massage, which some may find relaxing and stress-relieving, but nothing more. Any claims outside of that are not supported by the evidence.
You may not like the scientific evidence of course, but it is reinforced by the sheer implausibility of the claimed method of diagnosis and claimed mechanism of action for reflexology.
If you don’t agree with the scientific evidence, what do you base your assessment of reflexology on? What the professional associations tell you? Reflexology trade bodies? Your members’ websites?
There are a lot of doctors out there, but it can be difficult to know which are properly qualified and registered medical practitioners and who are, well, just quacks.
It’s not really that much of a problem for most of us. If we’re feeling unwell, we make an appointment with our GP. If there is any doubt about their status, you can always verify they are registered with the General Medical Council (GMC) by checking their List of Registered Medical Practitioners (LRMP).
But there are so many other ‘doctors’ out there. Ignoring The House Doctor®, The Car Doctor and others who have obviously got nothing to do with health, there are many who certainly like to give the impression they are proper doctors — and I have no doubt some of them think they really are.
Take homeopaths, for example.
A simple search of the business directory yell.com shows a large number of homeopaths using the title Dr. Of course, some of them are also medically qualified and on the GMC’s LRMP, but you don’t have to look far to find examples of non-medically qualified homeopaths calling themselves Dr. Again, I have no doubt many of them think they really are doctors and some may well have qualification that entitles them to prefix their name with Dr, but no one should be in any doubt of what they are.
In the UK, Dr is not a protected title: anyone with a suitable qualification can call themselves Dr so-and-so. This is in stark contrast to, say, chiropractors, which is a protected term and its use by anyone not registered with the General Chiropractic Council is illegal under the Chiropractors Act 1994.
Things, thankfully, are a bit stricter when it comes to advertising services to the public.
But there is an occasional interesting item or two.
The ASA Committee of Advertising Practice (CAP) – the debate goes on
The latest issue we’ve flagged up to the team at CAP relates to claims to treat minor sports injuries.
Its AdviceOnline in respect of osteopathy and physiotherapy states that CAP has accepted that they may claim to help minor sports injuries, but there is no mention of this for chiropractic. In respect of physiotherapy, CAP goes on to state that
“At the present time, CAP is unlikely to ask to see evidence for the treatment of minor conditions.”
We’ve asked CAP to confirm that it would take the same approach to any claims made by chiropractors about minor sports injuries. As ever, we’ll keep the profession in touch with progress.
We have the situation where the GCC — the statutory regulator for chiropractors, who frequently claim to be a primary health-care profession — is asking the ASA — the voluntary advertising regulator, funded through a levy on advertising spend — to add minor sports injuries back onto their list so their registered chiropractors can make claims about it!
Let’s see if we can help answer the GCC’s query.
When I submitted my complaints about claims made on chiropractic websites in June 2008, a fundamental requirement regulating what chiropractors could claim — firmly embedded in their Code of Practice — was that they only advertise consistent with guidance issued by the Advertising Standards Authority (ASA).
Chiropractors must justify public trust and confidence by being honest and trustworthy.
C1 Chiropractors must act with integrity and never abuse their professional standing.
C1.6 may publicise their practices or permit another person to do so consistent with the law and the guidance issued by the Advertising Standards Authority. If chiropractors, or others on their behalf, do publicise, the information used must be factual and verifiable. The information must not be misleading or inaccurate in any way. It must not, in any way, abuse the trust of members of the public nor exploit their lack of experience or knowledge about either health or chiropractic matters. It must not put pressure on people to use chiropractic.29
29 For example, by arousing ill-founded fear for their future health.
This clearly mandates chiropractors to ensure any advertising complies with ASA guidance, remembering that ASA guidance includes the CAP Code, other guidance and their adjudications.
In prosecuting my complaints, the GCC inexplicably forgot all about the requirement to be consistent with ASA guidance and came up with some arbitrary standard of evidence for compliance. The Professional Conduct Committee begged to differ even with that and effectively allowed any old evidence to be used to substantiate chiropractors’ claims. To understand the whole story, see Humpty Dumpty regulation.