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Unethical advertising

Following up my blogs on ‘post nominal letters’ and ‘profits before animal welfare’ there is something I want to say about ethics in advertising. It is a sad fact of life these days that people and groups will say things about themselves that infer they are something more than the hard truth would describe. In politics it is known as putting on a positive ‘spin’ and in slang terms it is known as ‘bigging up’. Either way, it is dishonest.

Sadly this practice has found its way into the word of animal welfare, in particular those advertising their services in the dog behaviour and training sector. I am sure that many do not understand what they are doing wrong or even that they believe it is perfectly acceptable but I am also sure that there are those who are well aware that they are bending the truth or not telling the whole truth in order to create an impression of superiority. You don’t have to look very far to find examples of unethical advertising though and here are some:

  1. The person has studied at a university and puts that university logo on their website. This infers that the university has endorsed their business which is highly unlikely and permission to use the logo has more than likely not been granted.
  2. An organisation that sends an email or letter to a government department offering advice then claims they are government advisors. Taken literally this might, at a stretch, be the case but the inference of the status claimed will be far from the reality.
  3. Using images of government funded services such as Police Dog Handlers or Home Office Dog Handlers in conjunction with courses or services implying that there is some form of formal relationship with such establishments when no such relationship exists.
  4. Claiming to abide by certain standards then ignoring them.
  5. Organisations that are at best, run by a few people (sometimes only one), who call themselves The British….or The National…..They are clearly not in the same league as British Aerospace or the National Trust but aim to deceive customers into thinking they are far bigger than they actually are.
  6. Making unsubstantiated claims about what they achieve.

Part of the problem is that the practice is so widespread it is seen as ‘normal’ and ‘acceptable advertising practise’ but I assure you it is not. It has reached a stage that being perfectly honest can give the image of being inferior when compared with the elaborate propaganda that the innocent investigator can be faced with. Let’s be clear about this, the practises I am describing are fraudulent, the definition of fraud being: ‘someone who deceives people by saying that they are someone or something that they are not’ (

To go one step further, Section 2 of the Fraud Act 2006 states that making false representations as to fact or the law either impliedly or expressly, being well aware that such representation is false for the purpose of deriving personal gain constitutes a criminal offence of fraud.

So, what is to be done? A start has been made by ABTC by publishing Ethical Advertising Guidelines which can be seen at:

These guidelines are actively being enforced, all organisations that are members of ABTC and their individual registered trainers and behaviourists have to comply. There have already been several cases of people having to amend their websites in order to come into line with requirements giving the public some chance of being able to make informed choices. This is regulation of trainers and behaviourists in action but sadly ABTC has no jurisdiction over non members yet, but I predict that the day will come when they do and the whole sector will be made to clean up their act.

To behave ethically is to know the difference between what you have a right to do, what is right to do and doing the right thing even when nobody is watching.

Why not punish?

Despite the dog training world slowly becoming more enlightened as the full benefits of positive reinforcement spread across the sector, it seems that there are still some out there promoting positive punishment as a viable training method. Newcomers are being taught methods that belong firmly in the last century despite all the information and research that points to more effective and humane methods. So why do the remnants of these outdated methods still linger on in some corners of dog training?

The first point to make clear is that positive punishment can work but (and it is a very big BUT) it has severe limitations and consequences which those who have an ounce of compassion and patience will regard as unacceptable.

The first problem is that positive punishment will result in what I call ‘learning in context’, in other words the learnt behaviour will only be exhibited in the context it was taught in, while the threat of punishment exists. An example would be a dog that is taught not to jump up by smacking him on the nose or kneeing him in the chest, he will stop jumping up to the trainer but will not generalise that behaviour to other people who do not deliver the same negative experience. It is no different with people driving, the whole driver safety education system revolves around punishment and the threat of punishment, take speeding for example. Speed cameras pose a threat of punishment and drivers ensure that they slow down when the threat is perceived but as soon as the threat is removed they speed up again.

The next issue is that of fear, anyone with a basic grasp of classical conditioning will understand that the pairing of an unconditional stimulus (pain) with a neutral stimulus (training venue) will lead to the training venue becoming the conditioned stimulus. In short, the dog predicts that entering the training venue will lead to pain and therefore elicits a fear response before any punishment has even been hinted at. No different than dogs becoming fearful of going to the veterinary surgery. It is also not beyond the bounds of possibility that something in the training venue (floor covering, noise, smells etc) will be generalised to other locations and the dog will unexpectedly become fearful for no apparent reason. The human equivalent would be fear of dentists, needles or even a dislike of a food or drink that made you ill. While fear can be a powerful component of classical conditioning it should have no part in training using operant conditioning, a process that drives the dog to work to achieve the desired behaviour rather than working to avoid punishment.

The other dimension of fear and other unpleasant stimuli is how they affect the capacity to learn. I am sure we all had a particular subject at school that we did not like, perhaps a teacher that was unkind or had an aggressive manner, inevitably this was a subject that we did not excel in, partly due to a lack of motivation but more importantly the readiness to learn is impaired by the state of stress during those lessons. Exactly the same principle applies to dogs, if it is fun there is motivation to perform, if it unpleasant the only motivation is to get it over as soon as possible or even disengage.

Some trainers will hide behind negative reinforcement in the belief that this clears them of inflicting positive punishment on the dogs. What often goes unmentioned however is that removing a negative stimulus requires a negative stimulus to be applied first, thus inflicting positive punishment before negative reinforcement can be exercised. In the case of a choke chain for example, the pressure of the collar on the throat cannot be released until it has first been applied and before the tightening collar is blamed on the dog pulling, take a look at who put the device on the dog. When negative reinforcement was first thought of by psychologists it was a process to describe how people might take an aspirin to remove a headache, or move into the shade on a hot day (as will dogs) not as a description of a useful training method.

Given the disadvantages of using positive punishment as a training method you might think that would be enough to avoid it but there are also good reasons why positive reinforcement should always be the method of preference. Firstly it creates a stronger bond between trainer and dog, secondly it cannot, by definition, include any unpleasant or cruel stimuli, lessons learned are readily generalised to other contexts, the learning will be more long-lived and the dog will ‘enjoy’ the process. The only possible downside (that is hardly worth mentioning) is that it may, in some circumstances, take a little longer for the learning to become established.

So why do people still use punishment as a matter of course? Possibly because the results (including the limitations and consequences) can possibly be achieved faster than by more humane means, possibly because the trainers do not fully understand the subject of learning, perhaps it is because they are told it is OK by people who are perceived by the uninformed as being something of an authority or perhaps they are unable to accept that what they have been doing for years is plain wrong. Whatever the reason, if they do not have the patience and knowledge to deliver training in a humane and informed manner that will enhance the handler/animal bond and be an enjoyable experience for both, they should perhaps consider the possibility that they have made an unsuitable career choice.

It is not a great leap from inflicting pain to abuse.

An explanation of Pre and Post-nominal letters

An explanation of Pre and Post-nominal letters

Accepted convention dictates that individuals may be authorised to display letters or abbreviations before or after their name indicating their social status or that they hold official appointments, honours, degrees or membership of learned societies.

Pre-nominal titles indicate profession (eg Doctor, Professor, Reverend), social title (eg Mr, Mrs, the Honourable, Sir), or military rank (eg Captain, Major, Sergeant).

Post-nominal letters indicate honours, appointments, degrees and memberships.

Honours and Awards cannot be in dispute as they are awarded by the government on behalf of the monarchy (MBE, CBE, VC, DFC).

Appointments include appointments to the Queen (ADC), politicians (MP, MEP) and legal positions (QC, JP)

Degrees awarded by universities (BSc, PhD).

Learned Societies limited to those holding a Royal Charter (MRCVS, FZS).

As this system is only bound by convention and not governed by law recent years have seen some practices that were not originally intended, drift into common usage.

Some qualifications other than degrees or are now awarded post nominal letters such as PGCE and Cert Ed but it should be noted that they are still awarded by universities or official regulatory authorities. A qualification is not simply any course of training or education, in order to be a qualification it must be one of two things:

  1. a) Academic. In order to satisfy academic criteria it must appear on one of the formal qualification frameworks approved by Ofqual or equivalent, this does not include what is known as customised provision which covers virtually all of the animal training and behaviour courses.
  2. b) Professional. An approved regulatory authority may award post nominal letters to those who have met the requirements to be recognised by that body as competent practitioners of their skill.

Anything that is not described by either of these two categories is not a qualification and should not legitimately attract post-nominal letters. If post nominal letters are associated with such courses they are usually issued by the course provider and not a professional authority, it is usually done for marketing purposes solely to infer a greater value or worth than actually exists.

Professions were historically limited to Religion, Medicine and Law however by the end of the 19th Century, Teaching, Social Work and peripheral occupations of the original three such as Nursing, Veterinary Medicine and Pharmacy also claimed professional status. In recent decades many have sought to trade off the social status afforded to established professions by altering the accepted meaning of ‘profession’ to simply that of a vocation that provides an income, thus completely undermining the original value in being a true professional. An indication that someone has successfully undergone the required education and training to be assessed as competent can be indicated by post nominal letters such as VN (Veterinary Nurse) or CEng (Chartered Engineer). In order to be a bona fide profession there must be an authoritative regulatory body with the power to decide upon appropriate levels of education and the right to admit and discipline members with some degree of monopoly of rights.

The proliferation of post nominal letters that indicate completion of courses that are self proclaimed is both confusing and without worth serving to simply undermine established traditional values, especially when many of the courses are set at little more (sometimes less) than the equivalent of a GCSE. Such letters are worthless and the deception is often perpetuated when people use their meaningless letters to appear highly qualified to unsuspecting pet owners. It would be laughable to place a list of GCSEs after your name on a business card and that is how most of these post nominal are regarded by those who are properly qualified.

David Montgomery

The real meaning of accreditation

I have written before about some of the topics surrounding quality education provision to try and help people through the maze of information and mis-information they are presented with. One topic that has come to the fore recently is the question of the different levels of accreditation that are available and what value they add (or not) to the courses they apply to.

Education is jointly regulated in England (Ofqual), Wales (DCELLS) and Northern Ireland (CCEA), in Scotland this role is carried out independently by SCQF. Their responsibility is to ensure that the quality of education that is delivered in schools and colleges is standardised. Education that leads to academic qualifications is then listed on a database and depending on the level that is attributed to it, it may contribute credit points (CAT points) to the successful students that would support university applications through UCAS. Collectively this is known as the Qualifications and Credits Framework (QCF). In addition Ofqual regulate Awarding Bodies to accredit provision that is not on the QCF which is known by a variety of names such as private provision or customised provision.

The first three points to note are:

  • Getting credits (CAT points) towards a university application is only of real value to those under 21 because applications for those older than that are classed as ‘mature’ and a broader look at the applicant’s life experience and other education is taken into consideration.
  • Credits awarded for customised provision do not count towards CAT points.
  • The QCF provision and customised provision is quality controlled in exactly the same way, the notion that more generous level attribution is found from some awarding bodies is absurd. It is more than their own awarding body status is worth to bend the rules.

There is another aspect that often gets overlooked and that is where vocational education leads to a professional qualification, in other words whether the subject being studied has to cover certain topics at levels specified by a regulatory authority. A prime example is the Veterinary Nursing qualification, it can only be studied at specified colleges and the course content is matched against the professional requirements before it is approved. Where the job is not regulated by a statutory authority eg dog training and behaviour, it makes absolutely no difference whatsoever whether the course is on the QCF or not because nobody but the course provider is saying that content is relevant or that it qualifies you to do anything. The only thing any kind of accreditation is doing is giving some level of assurance that the course will be delivered with appropriate academic rigour, nothing about the content.

One characteristic of getting courses on the QCF is that it is an expensive process and this is translated into the cost of undertaking the course so the long and short of it is that unless you are under 21 and want to use your studies to gain a place at university, the single difference between accredited private provision and QCF provision is the latter will be considerably more expensive. The problem of an authority approving courses for animal training and behaviour is about to be solved with the imminent launch of the ABTC course recognition process. This will map course content against the ABTC standards for a range of roles so that individuals will be able to tell which courses are going to deliver the right education for their needs and by exclusion, which ones might not be such a good investment.

On a final note I have also recently mentioned what it means to behave professionally and honourably in terms of not criticising competitors. My last observation that some people are making much of how they are operating within these most basic of professional standards yet hide behind private forums to pedal their unethical and biased stance to promote their own enterprise has since been evidenced on more than one occasion. In some ways it should help people decide who they should study with because such behaviour might indicate the level of integrity that is applied to the running of their educational establishment.

Self promotion and profit before animal welfare

When I became directly involved in animal welfare work around 17 years ago it became immediately clear that money was always going to play a part. People and businesses have to make money in order to contribute to their chosen aspect of animal welfare and continue to do so. What I was not prepared for was the unpleasant side of competition which seems to get worse in line with the size of profit people are chasing.

Initially there were very few course providers and the atmosphere was reasonably professional, competition was a good thing because everyone was trying hard to do better than the others, Compass introduced the concept of accreditation for courses and others soon followed for instance. As time passed it seems that almost anyone decided that this was something they could do to make a living and in recent years the number of course providers has mushroomed and they all offer courses that sound similar, some have accreditation, some do not, some are taught by people with teacher training, many do not. It was at this point, probably three or four years ago that things started to get decidedly unprofessional.

Even the process of accreditation is being abused now, what happens is, the provider joins an awarding body, gets some courses accredited then fails to achieve the required standard. Before they are dropped by the awarding body they leave and move on to another one and repeat the cycle every couple of years.

A couple of years ago Compass was subjected to outright copying of courses which were then falsely attributed with inflated levels so they would appear to offer more than the originals, I suppose we ought to be flattered but we are still stunned by what happened. It now seems that the only way to appear better than anyone else is to publicly criticise the competition, even when there is no basis whatsoever for such behaviour.

The introduction of professional codes of conduct should have dealt with some of this activity particularly as most state that the signatory must not ‘make claims of superiority or disparage colleagues or members of other organisations or professions’. Sadly this simply added another way for the unscrupulous to make themselves appear superior, they make a big point about signing up to a code of conduct as part of their sales talk, then simply ignore it!

More recently such unprofessional criticism seems to have become more subtle with the advent of closed internet forums which provide a breeding ground for rumours, misinformation and downright untruths. They are spread to unwitting members who repeat what they have been told more publicly believing it to be true.

What I would dearly like to know is when the motivation to educate in support of animal welfare became a scramble for bigger and bigger profits at any cost to integrity and professionalism? For many, contributing to animal welfare has become a very low priority.

Needless to say, Compass will keep on doing what it has always done, providing high quality courses at affordable prices that will truly contribute to people’s knowledge of animals. We will also not be lowered to the level of criticising other providers, spreading rumours or untruths, the quality of our courses always has and always will do the talking.

Why is there still confusion over regulating Behaviour and Training?

I am amazed how after five years since the start of a regulatory process in the field of animal behaviour and training there is still a lack of understanding at practitioner level about what is happening, who is going to be properly qualified, which organisations are recognised and recognised by which authorities.
There is a simple answer to the question ‘why is this the case?’ and that is that those who refuse to adopt the high standards that have been set by the ABTC continue to publish misinformation to justify their position (I would refer you back to my previous blog on unethical marketing). This is leaving individuals who are trying to find answers to their questions unable to make sense of it all and decipher what is correct and what is not. The sad result of this is that newcomers to the sector will invest time and money in training and education and many will eventually be very disappointed. They will discover that their efforts have been wasted because they have made decision based on information that is not entirely correct.
As far back as 2008 everybody that was asked agreed that standards were necessary and the series of talks chaired by CAWC followed in an attempt to create a regulatory system. Those talks broke down without any agreement other than for a basic code of conduct. The suggestion that any one organisation was in some way endorsed by CAWC as being the one to take the process on is a fantasy and anyone saying otherwise is at best hopelessly mistaken. No such endorsement was given although an encouraging letter was received from Lord Soulsby, the chairman of CAWC acknowledging the work and support that had been achieved by ABTC along with a similar email from the late sir Colin Spedding who chaired the meetings.
One of the most ridiculous notions out there is that there is a difference between an animal behaviourist and a canine behaviourist. This is really clutching at straws in a desperate attempt to somehow make a distinction between the two The real distinction is between those who have adopted the high standards of the ABTC and those who choose to remain outside of a process that is supported by the veterinary profession (BSAVA, BVA, BVNA) and the government (Defra). Any title that includes the word animal does so to allow for the speciality of any species, a quick glance at the list of speciality species on any of the ABTC registers will show that the vast majority of registered practitioners specialise in dogs. I should add however that even if someone only wants to deal with dogs there is an absolute need to have some knowledge of other commonly kept species because they frequently form part of the dog’s social environment and to not have that knowledge means you are not properly qualified to deal with such cases.
The fact remains that there are only two organisations that Defra refer the public, the police and local authorities to when there is need for trainers and behaviourists and they are the Kennel Club (those qualified under the KCAI scheme) and the ABTC (full members of approved organisations) and nobody else. Others have made representations to be included but they have been rejected, I would invite my readers to draw their own conclusions about the reasoning behind such omission.
The result of misinformation is that people are being confused in an otherwise very clear situation, make no mistake, the process is gathering pace and those who are able to distinguish between the reality of that and the multitude of nonsense that persists will be able to make wise decisions.

Unethical marketing

Unethical marketing has long been a subject that has irritated me, particularly where animal services and associated activities are concerned because ultimately it is the animals and unwitting users of services that end up paying the price. Finally the ABTC has a code of conduct to address this issue (see
The main trick that is employed by the unscrupulous marketers is making misleading statements or inferring something that is not quite true. This is the grey area between telling the truth and being downright untruthful which creates a mental image about the product or service that the writer wants readers to conclude despite it not actually being the case. The defence that is offered for such marketing practices is ‘the advert/article does not actually say that’ although it doesn’t take too much grey matter to see what image the writer wants to create.
In professional marketing terms the word that describes this practice is ‘puffery’, which means the product or service is ‘puffed up’ to make it look better, bigger, more successful or sophisticated than it is in reality. A hypothetical example might be when someone writes a letter to a major dog rescue charity suggesting a method of behaviour assessment and subsequently claims in their marketing material that they have advised said charity, a statement that is not technically untrue yet creates a false impression to the reader.
Another darker practice that I see from time to time is negative marketing, this is when people seek advantage by telling their audience how bad their competition is, being outright critical. There is no excuse for this. If someone cannot offer reasoned argument for their preference and allow their audience to make up their own mind it says more about the writer than the target of their criticism. What compounds this misconduct is when perpetrators sign up to a code of practice that does not allow such behaviour yet they continue to do it anyway.
The advent of the internet has made the situation considerably more prolific because now it is so easy and cheap to spread misleading statements to a huge audience and the more ‘professional’ a website looks, the greater air of credibility it lends to the message being put forward. There is, a practice known as Search Engine Optimisation, which website managers use to get their sites further up the rankings when a search is made. This is open to all sorts of abuse and ‘black hat’ methods. A method is referred to as ‘black hat’ when something is created out of nothing, like a magician pulling a rabbit from a hat. Without getting into the technicalities involved it essentially telling lies about the product or service in the background so that search terms that people type in are directed to that site more frequently than others, thus pushing the site nearer to the No 1 spot. This can, of course, be achieved legitimately by simply providing the complete service that is stated and attracting genuine searches but the reader will never be sure until they actually sign up to what is being offered. I was even stunned to discover that it is possible to buy ‘likes’ on Facebook in order to make a page look far more popular than it actually is.
It boils down to a matter of conscience and honesty but there is constant pressure to compete and it is very difficult for those who do so in a truly moral fashion when faced with those that push the ethical boundaries. It has always been my belief that a reputation built on being truthful and fair is the only way to be because any short term gains achieved by behaving otherwise will eventually come back to haunt you.

To behave ethically is to know the difference between what you have a right to do, what is right to do and doing the right thing even when nobody is watching.

David Montgomery