On the 5th of December 2016, I published a video showing members of the Church of Scientology Plymouth (UK) distributing leaflets outside of Charles Cross Police station. This is just around the corner from their modest Org in Ebrington Street.
In the process, I was given a flier, and carefully read it. It seemed to me that the text made two highly questionable claims.
According to the rules of the UK advertising regulator (the Advertising Standards Authority) advertisers who make specific, testable claims must be in possession of objective evidence which supports their case. If the advertiser cannot present such evidence when asked to do so by the ASA the claims made are deemed to be misleading, and must not be repeated.
I duly submitted a complaint online. Yesterday, I was informed that it has been upheld.
This kind of decision could severely limit Scientology’s ability to make similar claims in future – and could ultimately force them to submit whole classes of promotional material to the ASA for pre-approval.
All that is required is for more people to collect Scientology advertising containing potentially misleading claims.
Details of the offending leaflet, my complaint, the ASA response and the likely consequences appear after the break.
The front and back of the leaflet in question is reproduced below. If you click either image, a larger version will appear in a new tab, so you can examine it in detail.
Here is the text of the complaint that I submitted to the ASA online.
The leaflet states that “Using the processes of this book you could, “achieve improved memory and reaction time”.
These are specific, testable claims, and I understand that the ASA requires advertisers to be in possession of reliable objective evidence to support claims of this nature.
I submit there is significant doubt that a book of this nature could perform as advertised. Consequently, the Church of Scientology Plymouth should be required to present objective evidence in support of the claims made for it, or withdraw this aspect of the advertisement.
A copy of the leaflet in question has been provided in the form of two links to scans of the front and back. The original can be provided upon request, as well as video showing members of the Church of Scientology Plymouth distributing the leaflets.
The ASA took me up on the offer of the video, which I provided.
The leaflet itself clearly shows that the book in question was being offered for sale by a Scientology Org that is literally a few minutes walk away.
If that was not enough, the video shows Org staff using a handcart to offer copies of “Self Analysis” for direct sale. These can be seen at 9′ 40″(alongside copies of “Dianetics”).
As an aside – as far as I am aware, the Church of Scientology does not posses a licence for street trading – but that’s another matter.
If you watch the video, you will see a staff member taking many photographs of the proceedings. It’s likely that these were required by ‘head office’ for promotional purposes, and obtaining them was the real object of the exercise. To do so, Org staff had to take a chance. They have certainly not been seen on the streets since.
If anyone comes across a Scientology publication which shows Plymouth Scientologists ‘disseminating’ to the local population, I would be extremely interested.
The ASA Response
The ASA’s final decision was as follows:
Thank you for your recent enquiry about advertising for the Church of Scientology Religious Education College Inc. You explained that you believe the ad is misleading because you don’t believe that the claim “Using the processes of this book you could achieve improved memory and reaction time” can be substantiated.
We’ve assessed the ad you highlighted and, from the information we have, we think it likely to have breached the Advertising Codes (“the Codes”) that we administer. We are writing to let you know that we have taken steps to address this.
We have explained your concerns to Church of Scientology Religious Education College Inc and told them to remove the claim you complained about from their advertising. We also provided them with advice on how to ensure that their future advertising complies with the Codes.
Thank you once again for taking the time to raise your concerns with us. Comments such as yours help us to understand the issues that matter to consumers and we will keep a record of your complaint on file for use in future monitoring. If you would like more information about our complaint handling principles, please visit our website at https://www.asa.org.uk/Consumers/How-to-complain.aspx.
What Does This Mean?
When the ASA receives a complaint, they will typically open an informal investigation. If the complaint is upheld, they will contact the advertiser. If the advertiser agrees to withdraw the offending material, and does not repeat the offence. the matter is considered closed.
The ASA will give advertisers advice about how to avoid similar situations in future – and the benefit of the doubt.
This is what has happened in this case. It does not seem to be much. However, if Scientology repeats this claim, and a complaint is made about that, the ASA will escalate to a formal investigation. This can impose more serious sanctions – for Example, the advertiser can be ‘named and shamed’ on their website. Ultimately the Church can be required to submit material to the ASA for approval before publication.
Consequently, if you come across any UK promotional material from the Church of Scientology that makes an objective claim about the benefits of Scientology, a complaint against it is very likely to succeed. It’s only a matter of identifying material where such claims are made.
If you come across such a claim in any publication (newspaper, magazine, poster, leaflet, flier &c) please inform me here. If it can be established that the Church of Scientology continue to make questionable claims despite assurances to the contrary, they can be subjected to significant sanctions.
This approach takes time and patience – but it does get results. For example, I have made a number of successful complaints and documented them on this site.
- After my detailed complaint against “Narconon Scotland“, which operated online, was upheld, the website closed down. I believe this closure was a direct consequence of the complaint.
- Another complaint about a press advertisement misleadingly comparing the activities of Scientology’s ‘volunteer ministers’, o relief organisations such as the Red Cross, was sanctioned by the ASA, and their decision was permanently recorded on the ASA website.
- This complaint, against a flier handed out in the street, makes it a hat trick. I believe that there is considerable mileage to this approach, of more people could be persuaded to take action.
Curiouser and Curiouser…
In these circumstances, the Church of Scientology does not help itself – in fact, it very often shoots itself in the foot. In this case it has made a serious tactical error.
Scientology is a very hierarchical organisation. The people at the Plymouth Org likely had no choice but to refer my complaint to their superiors. The ASA confirm this when they state that they received assurances from the “Church of Scientology Religious Education College Inc” (COSRECI) which controls Scientology in the UK.
This means that the assurances given were not made by Plymouth Org. They were made by the organisation that controls Scientology in the UK, and consequently apply to all Scientology entities in the UK. If any Org issues hands out the same leaflet, Scientology has failed to honour the assurances given, and a complaint about that would have much greater weight.
*PS: COSRECI is actually an Australian organisation, and the Church of Scientology in the UK is nominally administered from Australia. For an explanation of this strange tax avoidance scheme see the appendix at the bottom of the page.
The effect of such a complaint is not limited to the bad PR which results when Scientology is found to have published a misleading advertisement by the official UK regulator.
- The fliers must be redesigned and reprinted
- The remaining stock cannot be used without breaking the undertaking made with the ASA – they must be destroyed.
Since such things are designed an distributed on a national basis, having to scrap a leaflet can incur significant costs. Orgs are required to buy the leaflets they distribute from the parent organisation, so this places a considerable extra burden upon their meagre income.
Finally, any successful complaint places personal pressure upon grass-roots Scientologists.
When it appears to fail this can only be because has not been properly applied. The only reason for this (which is acceptable to the organisation) is that the Scientologists who were entrusted with a task were compromised.
Hubbard asserted that the Scientologist(s) in question must have committed a ‘sin’ against Scientology. This is called an ‘overt’ . Worse yet, they could also confess in a timely manner. In that case, they are compromised by a ‘withhold’. Overts and withholds are a central part of Scientology doctrine.
From Scientology’s point of view, the fact that a complaint against them has been upheld is not my responsibility for having made it. I’m merely a ‘suppressive person’ who could not possibly be capable of doing something that could impact Org operation.
The failure to prevent such a thing happening is deemed to be the fault of the Scientologists on the spot for not having applied Scientology properly because they carry overts and withholds.
Hubbard’s circular argument goes like this: if the Scientologists in the spot had been applying Scientology correctly, nothing bad could possibly happen. Consequently, whenever something bad does happen, it is their fault. They are told that they have ‘pulled it in’.
Consequently, staff are punished whenever something does wrong, even if it not their fault, even if it is a consequence of obeying orders from above (which seems likely in this case).
These punishments can have quite serious consequences, and a few are listed below.
This has happened to Plymouth Org several times in the recent past. For example, when staff proved incapable of controlling the activities of a local protester, they were forced to endure several Sea Org missions and expected to finance them. A senior Scientologist at the Org was also humiliatingly demoted.
‘Security checking’ of Scientologists may also take place. This practice involves an interrogation, using the e-meter as a kind of lie detector.
Scientologists who implicitly believe in the power of this device will be pressured to make all kinds of humiliating unlikely confessions because they believe it to be infallible. These confessions will be recorded on their permanent record.
Finally, Scientologists may be assigned low ‘conditions‘ and also required to retake Scientology ‘courses’. These measures can be arduous and (if you are not ‘on staff’) very expensive. People might also be pressured to make reparation with a cash donation.
To be honest, the fact that my complaint may have such serious consequences for local Scientologists makes me uncomfortable. However, Scientology’s attitude is similar to that of a hostage-taker. They can’t punish me, so they will punish the people under their control. That is their choice, not mine.
I can only hope that the injustice of this kind of action will make local Scientologists begin to question whether this organisation deserves their loyalty.
*Appendix 1: The Church of Scientology’s Tax Avoidance Scheme
In the 1990’s Scientology registered, “The Church of Scientology England and Wales”and applied for charitable status, which confers considerable tax concessions. The Charity Commission, who administer such things, refused this in a decision which was so watertight that even the notoriously litigious Church of Scientology did not bother to appeal (the detailed decision can be read here).
Scientology responded by registering “The Church of Scientology Religious Education College, Inc. (Australia)” AKA COSRECI. By transferring the UK operation in an Australian state which recognises Scientology as a religion, the Church avoids paying UK income tax – in fact, they avoid paying any income tax at all.
To minimise liability, every UK Org is registered independently and operates under the umbrella of COSRECI. In practice, the Church of Scientology is a very hierarchical organisation. Any decision that does beyond everyday operation must be referred to their superiors.
The ASA response to my complaint states that they dealt with the “Church of Scientology Religious Education College Inc” (COSRECI) so the local Org must have passed it on.
Details of The ASA’s rules and how to make an online complaint appear in a previous post. It concerns an advertisement in the UK magazine “New Statesman” regarding Scientology’s ‘Volunteer Ministers’, but the process is the same for any complaint.