Denis Naughten uses Public Funds for Personal Electoral Gain


  1. 16th June 2016 – Denis Naughten says Eircode is saving lives.
  2. 21st June 2016 – The Journal Fact Check says “Denis Naughten could not provide evidence to support his claim”
  3. 29th June 2016 – Public service announcement was being filmed showing Eircode being used by National Ambulance Service the ONLY emergency service currently equipped to  use the flawed Eircode, and only for dwelling based emergencies.
  4. 30th November 2016 – ASAI rule that advert is deliberately misleading, exploitative & unsubstantiated.


RE: Advertising for Eircode – Emergency Services


The radio and television advertising featured the same script; the only difference being the television advertisement featured visual content.


On-screen text: “Public Service announcement”

A telephone operator is speaking on the phone in an ambulance call centre with her keyboard at the ready to input the details of the Emergency. The conversation ensued as follows:

“Operator: Ambulance emergency. Can you confirm your phone number?

Male Caller: My mother has collapsed. She’s breathing but not responding.

Operator: Ok. What’s the address of the emergency? Male Caller: She’s only just moved here. It’s near Kilmac.

Operator: Don’t worry, do you have an Eircode? It will help us find you faster.

Male Caller: Hang on, it’s here beside the phone. Its A65F4e2”

The call filters through to the ambulance crew who are already on the road, the operator informs them where to go and the Eircode provided flashes on the screen.

“Operator: It’s ok. I’ve got your location. We’ll be with you as soon as possible. I’m going to help you until they arrive”.

Two paramedics are then featured walking towards the house where the Emergency has occurred; a man is waiting at the door to meet them.

Male Voice Over: “Use Eircode and help the emergency service find you faster”. The on-screen text reads:


Find life easier. Visit the finder at”




Complaints in this case were received from consumers, one of whom was a former naval officer, now running a Location Codes business providing location codes for use with modern technology.

Further complaints were received from The Irish Fire Services Association (IFSA) and Ms. Lynn Boylan, MEP.


Consumer Complaints:

Consumer complainants considered the advertising to be misleading in content. Some considered that there was no evidence to support the implication that the use of Eircode would help emergency services reach their destinations faster and thus save lives.

Some complainants considered that Eircode were misrepresenting themselves as a Government Body by using the on-screen reference to “Public Service Announcement”. One complainant said that the use of the National Ambulance Service imagery and language created the false impression that the advertising was being delivered in the interest of public safety when in fact it was purely a commercial undertaking. Furthermore, this complainant also considered that the advertising gave the impression that the ambulance service control would act entirely on the basis of the Eircode provided which was not the case as an address/location also had to be provided.

The Irish Fire Services Association (IFSA):

The IFSA raised similar issues as the consumer complainants and were concerned that the implication derived from the advertisement was that it was a public service announcement. They considered that the advertisers were playing on people’s fears at the time of an emergency by bringing the emergency services into the equation, when in actual fact the premise behind the advertising was to encourage people to use their Eircode.

The IFSA said that in the case of an emergency the “Blue Light” services – An Garda Síochána, fire and Irish Coast Guard could be contacted by dialling 112 or 999; these were generally referred to as the Emergency Services. They said it had to be pointed out that Dublin Fire Brigade responded to just under 50% of all 999/112 Emergency calls. They said, however, that of the statutory emergency services mentioned only the HSE National Ambulance Service could currently use the Eircode Prefix in the mobilisation of resources to a medical emergency and then only when this emergency had occurred at a property. All other emergency services were not currently compatible with the use of the Eircode system.

The IFSA also said that The Commission for Communications Regulation (ComReg) who were obliged by law to monitor the quality of the Emergency Call Answering Services, when providing information on how to use the services correctly, made no reference to the use of Eircode when dialling such services. Likewise they said the HSE website under the National Ambulance Service section, the only statutory agency to use the Eircode prefix, made no reference to having to provide an Eircode when requesting such services.

Ms. Lynn Boylan, MEP

Ms. Boylan also raised similar issues as the consumer complainants and the IFSA. She raised one further concern in relation to the fact that one of the issues raised in relation to the Eircode service was the accuracy of some of the codes provided to some households. She was concerned that if some households had been provided with the incorrect code that this may only become apparent during an emergency situation and result in disastrous consequences.


Advertisers’ Response:

The advertisers said their advertising had been referred to as a Public Service Announcement (PSA) and they had never made any reference to it being a Public Safety Message. They said their PSA depicted a situation in which a caller contacted the National Ambulance Service in a medical emergency. They considered it to be very clear that the service involved in using the Eircode service was the Ambulance Service. They said no other emergency service personnel had featured nor had any other emergency service vehicles been used.

The advertisers said their PSA had been researched and filmed with the full consent and approval of the Health Service Executive (HSE), the National Ambulance Service and the Department of Communications, Climate Action and Environment. They said the conversation, which ensued during the course of the PSA between the caller and the call taker, resulted in an ambulance being dispatched to the location of the emergency. They said their PSA had not made any claim in relation to “saving lives”. They said, however, for members of the Public who had concerns in relation to safety, they made it very clear through their Frequently Asked Questions Section of their website that the ambulance service would still be dispatched to those who were unable to provide an Eircode.

They said in February 2016 the National Ambulance Service had updated their Computer Aided Dispatch system to enable the use of Eircodes when presented by callers dialling 112 and 999. As a result of these updated systems and processes, the advertisers said they considered that a PSA was required to inform the general public of the value of having an Eircode, which would assist them in efficiently providing the accurate location of their address should an emergency situation arise.

The advertisers said their PSA had been filmed in a number of locations:

·       On site at the National Ambulance Service Centre in Tallaght

·       On roads around Bray showing an ambulance on route to an emergency and

·       at a rural location in Wicklow showing the arrival of the ambulance crew at the address.

The advertisers said the script used for their PSA had been aligned as closely as possible to the scripts used by call takers in the National Ambulance contact centre and had focussed on the parts of the call where an Eircode was requested. They said the script had not included any statement in relation to “saving lives”.

In relation to the concerns raised that Eircode would not be of use for locating an emergency on road, land or sea, the advertisers said that this was in fact correct. They said, however, that their PSA had specifically focussed on a caller giving an address and the ambulance crew arriving at that address. They had never demonstrated the Eircode system being used in any other scenario.

Prior to the introduction of Eircode, the advertisers said that it had been standard practice in the National Ambulance Service contact centre, for call takers to ask for detailed directions to locate a specific address. They said that over 800,000 addresses in Ireland were “non unique” which meant that the same address was shared by more than one property. This situation combined with many addresses having no house number or house name, made it difficult to determine the exact location of the address. In order, therefore, for an exact location to be determined, call takers were previously required to ask for specific directions to a property, thereby taking valuable time and potentially causing additional stress to those in an emergency situation.


The advertisers said that having access to an Eircode allowed call takers to immediately identify and confirm an exact location for an address without having to take directions.

In relation to Ms. Boylan’s comments on the accuracy of the allocation of the Eircode, the advertisers said that the National Ambulance Service had introduced a process which validated the Eircode against the address and could identify any discrepancies or issues. Should any issues arise then call takers would revert to their former procedures to ensure the efficient and effective dispatch of their ambulances. They said this validation process was also referred to under their Frequently Asked Questions Section of their website. They said their website also allowed viewers to view the location associated with their Eircode.

The advertisers said that as a result of their PSA, there has been an unexpected increase in both traffic on the Eircode website and calls to the Eircode contact centre. The increase in contact with Eircode was predominantly from people asking for assistance in finding their Eircode location. They said they had also recently introduced a printed card service whereby members of the Public had been provided with a plastic card to have their Eircode available, particularly for use in situations such as that depicted in their PSA.

Code Sections: 7th Edition

2.4            (c) Compliance with the Code is assessed in the light of a marketing communication’s probable effect when taken as a whole and in context. Particular attention is paid to:

·       the characteristics of the likely audience

·       the media by means of which the marketing communication is communicated

·       the location and context of the marketing communication

·       the nature of the advertised product and the nature, content and form of any associated material made available or action recommended to consumers.

4.1       A marketing communication should not mislead, or be likely to mislead, by inaccuracy, ambiguity, exaggeration, omission or otherwise.

4.4       Advertisers should not exploit the credulity, inexperience or lack of knowledge of consumers.

4.9             A marketing communication should not contain claims – whether direct or indirect, expressed or implied – which a consumer would be likely to regard as being objectively true unless the objective truth of the claims can be substantiated.

4.10         Before offering a marketing communication for publication, advertisers should satisfy themselves that they will be able to provide documentary evidence to substantiate all claims that consumers are likely to regard as objective. Relevant evidence should be sent without delay if requested by the ASAI and should be adequate to support both detailed claims and the overall impression created by the marketing communication.


Executive’s Recommended Conclusion:

The Executive of the ASAI recommends that the Complaints Committee adopt the following text as their consideration of the case:

“The Complaints Committee considered the details of the complaints and the advertisers’ response. They noted the advertisers’ reference to the fact that their marketing communication was a Public Service Announcement (PSA) and had not stated that it was a Public Safety Announcement. Whilst Eircode were a commercial entity, the Committee noted that the advertising had been researched and filmed with the full consent and approval of the Health Service Executive, the National Ambulance Service and the Department of Communications, Climate Action and Environment.

The Committee noted that the advertising had only depicted an ambulance service and did not therefore consider that there was implication that all the emergency services used Eircode in address verification. Likewise, they did not consider that the advertising implied that Eircode could be used for anything other than property identification


The Complaints Committee noted that the advertisement had stated “Do you have an Eircode? It will help us find you faster” and “Use Eircode and help the emergency service find you faster”; both statements were definitive rather than conditional statements. They noted the advertisers’ explanation in relation to address identification and verification, but considered that evidence demonstrating that the use of Eircode would result in faster address identification location had not been submitted. The Committee were also concerned at the implication that having an Eircode was now necessary for callers to the National Ambulance Service.

The Committee noted that the advertising had not made any specific claim in relation to ‘saving lives’, but were concerned that it was implied that if people in need of the service could be found faster, then there was the potential to save lives.

In the circumstances, the Committee considered the advertising to be in breach of Sections, 4.1, 4.4, 4.9 and 4.10 of the Code.”

The Executive recommends that “the complaints should be upheld”.


Action Required

The Executive recommends to the Complaints Committee that they adopt the following action as the required action(s) arising from their consideration of this case.

“The advertising (PSA) should not be used in its current form again.”