The broadcast, on 25 November 2015, featured a girl visiting Father Christmas in his grotto. When asked what she would like for Christmas, the girl requested a puppy but her mother had told her that they did not have time to look after one.
Father Christmas replied, "How about a special Guide dog puppy like Snowy? Your Mummy can sponsor one like her for just £1 a week. You'll get photos, pupdates [sic] and a cuddly toy, then one day when Snowy's all grown up, she'll change a blind or partially sighted person's life forever!" He continued, "If you want to sponsor a guide dog puppy for someone special this Christmas, text SANTA to [telephone number] or visit [website address] ... and tell them Santa sent you."
A listener complained to the Advertising Standards Authority that the ad was likely to target children and encouraged them to ask their parents to make a purchase on their behalf.
When contacted by the ASA, the GDBA said the ad was aimed at adult listeners and encouraged parents to consider sponsoring a puppy as a Christmas gift.
Radiocentre felt that, whilst the ad included "Santa" and a child voice-over, listeners would understand that the message of the ad was about adult sponsorship only of a guide dog puppy via the reference: "Your mummy can sponsor a puppy".
In its ruling published today, the ASA said the ad did not breach BCAP Code rule 5.9, which prohibits ads from directly exhorting children to buy a product and rule.
However it did find the ad in breach of rule 16.3.4, referring to charities, which says: "Advertisements seeking donations for … a charitable body must not address fund-raising messages to children or [be] likely to be of particular interest to them".
The ASA said: "We acknowledged the ad stated that the child's mother would need to sponsor the puppy and puppy sponsorship was suggested as a Christmas gift more generally. However, we considered the ad addressed the adults and parents who might be listening to explain how they could find out more information about puppy sponsorship only at the end of ad.
"The majority of the ad's dialogue took place between the child and Father Christmas, explaining that the child’s mother could buy a puppy sponsorship so that the child could still 'receive' a dog for Christmas and the benefits that came with that. For the reasons given above, we concluded the ad was also addressed to children."