Aggregate numbers and the Boots ruling

You can quote your acceptance rate. Can you count the customers who withdrew, and say why?

Aggregate numbers are how firms hide from their own customers. The ASA has just proved it with a face cream costing £22.95.

Boots offered a free No7 lotion through a one-day voucher in a Sunday newspaper. One customer’s store had run out. One complaint. Upheld in August 2026.

Here is the detail worth sitting with. Boots showed that total stock exceeded total demand across their whole estate. They still lost. The ASA looked past the aggregate and asked whether each store gave each customer a fair chance on the day. And it found Boots had no system for recording when a customer walked away empty handed, which meant they could not learn from past promotions or allocate stock properly for the next one.

Two principles fall out of that. Being sufficient in aggregate is not the same as being fair to individuals. And not measuring your failure rate is itself the failure.

Thirty four years ago Hoover learned the expensive version of this lesson with free flights, at a cost to its parent Maytag of around £48m. The cheap version has just been taught with a face cream. This is why I read ASA rulings most weeks. They are a treasure trove of understanding businesses and consumers, and they are free.

Here is my problem. Our industry still reports itself in averages. Acceptance rates, mean settlement times, aggregate satisfaction scores. I have rarely met a firm that could tell me how many customers simply gave up. The ones who rang twice, got nowhere, and stopped.

They appear in no dashboard. The Consumer Duty’s focus on foreseeable harm is, to my eye, aimed squarely at them.

If you cannot count the customers who withdrew, your aggregate numbers are not evidence of good outcomes. They are the absence of evidence.