program areas Digital Youth

Citing research that illustrates a number of serious risks to children and teens in the Metaverse, advocates say Meta must wait for more research and root out dangers before targeting youth in VR. BOSTON, MA, WASHINGTON, DC and LONDON, UK — Friday, April 14, 2023 — Today, a coalition of over 70 leading experts and advocates for health, privacy, and children’s rights are urging Meta to abandon plans to allow minors between the ages of 13 and 17 into Horizon Worlds, Meta’s flagship virtual reality platform. Led by Fairplay, the Center for Digital Democracy (CDD), and the Center for Countering Digital Hate (CCDH), the advocates underscored the dearth of research on the impact of time spent in the Metaverse on the health and wellbeing of youth as well as the company’s track record of putting profits ahead of children’s safety. The advocates’ letter maintained that the Metaverse is already unsuitable for use by children and teens, citing March 2023 research from CCDH which revealed that minors already using Horizon Worlds were routinely exposed to harassment and abuse—including sexually explicit insults and racist, misogynistic, and homophobic harassment—and other offensive content. In addition to the existing risks present in Horizon Worlds, the advocates’ letter outlined a variety of potential risks facing underage users in the Metaverse, including magnified risks to privacy through the collection of biomarkers, risks to youth mental health and wellbeing, and the risk of discrimination, among others.In addition to Fairplay, CDD, and CCDH, the 36 organizations signing on include Common Sense Media, the Electronic Privacy Information Center (EPIC), Public Citizen, and the Eating Disorders Coalition.The 37 individual signatories include: Richard Gephardt of the Council for Responsible Social Media, former Member of Congress and House Majority Leader; Sherry Turkle, MIT Professor and author of Alone Together and Reclaiming Conversation; and social psychologist and author Jonathan Haidt.Josh Golin, Executive Director, Fairplay:“It's beyond appalling that Mark Zuckerberg wants to save his failing Horizons World platform by targeting teens. Already, children are being exposed to homophobia, racism, sexism, and other reprehensible content on Horizon Worlds. The fact that Mr. Zuckerberg is even considering such an ill-formed and dangerous idea speaks to why we need Congress to pass COPPA 2.0 and the Kids Online Safety Act.”Katharina Kopp, PhD, Deputy Director, Center for Digital Democracy:“Meta is demonstrating once again that it doesn’t consider the best interest of young people when it develops plans to expand its business operations.  Before it considers opening its Horizon Worlds metaverse operation to teens, it should first commit to fully exploring the potential consequences.  That includes engaging in an independent and research-based effort addressing the impact of virtual experiences on young people’s mental and physical well-being, privacy, safety, and potential exposure to hate and other harmful content.  It should also ensure that minors don’t face forms of discrimination in the virtual world, which tends to perpetuate and exacerbate ‘real life’ inequities.”Mark Bertin, MD, Assistant Professor of Pediatrics at New York Medical College, former Director of Developmental Behavioral Pediatrics at the Westchester Institute for Human Development, author of The Family ADHD Solution, Mindful Parenting for ADHD, and How Children Thrive:“This isn't like the panic over rock and roll, where a bunch of old folks freaked out over nothing. Countless studies already describe the harmful impact of Big Tech products on young people, and it’s worsening a teen mental health crisis. We can't afford to let profit-driven companies launch untested projects targeted at kids and teens and let families pick up the pieces after. It is crucial for the well-being of our children that we understand what is safe and healthy first.” Imran Ahmed, CEO of the Center for Countering Digital Hate:“Meta is making the same mistake with Horizon Worlds that it made with Facebook and Instagram. They have prioritized profit over safety in their design of the product, failed to provide meaningful transparency, and refused to take responsibility for ensuring worlds are safe, especially for children.“Yet again, their aim is speed to market in order to achieve monopoly status – rather than building truly sustainable, productive and enjoyable environments in which people feel empowered and safe.“Whereas, to some, ‘move fast and break things’ may have appeared swashbuckling from young startup entrepreneurs, it is a brazenly irresponsible strategy coming from Meta, one of the world’s richest companies. It should have learned lessons from the harms their earlier products imposed on society, our democracies and our citizens.”horizonletter.pdf

Coalition of child advocacy, health, safety, privacy and consumer organization document how data-driven marketing undermines privacy and welfare of young peopleChildren and teenagers experience widespread commercial surveillance practices to collect data used to target them with marketing. Targeted and personalized advertising remains the dominant business model for digital media, with the marketing and advertising industry identifying children and teens as a prime target. Minors are relentlessly pursued while, simultaneously, they are spending more time online than ever before. Children’s lives are filled with surveillance, involving the collection of vast amounts of personal data of online users. This surveillance, informed by behavior science and maximized by evolving technologies, allows platforms and marketers to profile and manipulate children.The prevalence of surveillance advertising and targeted marketing aimed at minors is unfair in violation of Section 5. Specifically, data-driven marketing and targeted advertising causes substantial harm to children and teens by:violating their privacy;manipulating them into being interested in harmful products;undermining their autonomyperpetuating discrimination and bias;Additionally, the design choices tech companies use to optimize engagement and data collection in order to target marketing to minors further harm children and teens. These harms include undermining their physical and mental wellbeing and increasing the risk of problematic internet risk. These harms cannot reasonably be avoided by minors or their families, and there are no countervailing benefits to consumers or competition that outweigh these harms.Surveillance advertising is also deceptive to children, as defined by the Federal Trade Commission. The representations made about surveillance advertising by adtech companies, social media companies, apps, and games are likely to mislead minors and their parents and guardians. These misrepresentations and omissions are material. Many companies also mislead minors and their guardians by omission because they fail to disclose important information about their practices. These practices impact the choices of minors and their families every day as they use websites, apps, and services without an understanding of the complex system of data collection, retention, and sharing that is used to influence them online. We therefore urge the Commission to promulgate a rule that prohibits targeted marketing to children and teenagers.Groups filing the comment included: The Center for Digital Democracy, Fairplay, and #HalfTheStory, American Academy of Pediatrics, Becca Schmill Foundation, Berkeley Media Studies Group, Children and Screens: Institute of Digital Media and Child Development, Consumer Federation of America, Consumer Federation of California, CUNY Urban Food Policy Institute, Eating Disorders Coalition for Research, Policy & Action, Enough is Enough, LookUp.live, Lynn’s Warriors, National Eating Disorders Association, Parents Television and Media Council, ParentsTogether, Peace Educators Allied for Children Everywhere (P.E.A.C.E.), Public Citizen and UConn Rudd Center for Food Policy & Health FairPlay's executive director Josh Golin said: "Big Tech's commercial surveillance business model undermines young people's wellbeing and development.  It causes kids and teens to spend excessive time online, and exposes them to harmful content and advertising targeted to their vulnerabilities. The FTC must adopt a series of safeguards to allow vulnerable youth to play, learn, and socialize online without being manipulated or harmed. Most importantly, the Commission should prohibit data-driven advertising and marketing to children and teens, and make clear that Silicon Valley profits cannot come at the expense of young people's wellbeing.”CDD's Jeff Chester underscored this saying: "Children and teens are key commercial targets of today’s data-driven surveillance complex.  Their lives are tethered to a far-reaching system that is specifically designed to influence how they spend their time and money online, and uses artificial intelligence, virtual reality, geo-tracking, neuromarketing and more to do so.  In addition to the loss of privacy, surveillance marketing threatens their well-being, health and safety. It’s time for the Federal Trade Commission to enact safeguards that protect young people. "[full filing attached]

At every turn, young people face tricks and traps to keep them online for hours and sharing sensitive data. Contact:David Monahan, Fairplay: david@fairplayforkids.orgJeff Chester, Center for Digital Democracy: jeff@democraticmedia.orgAdvocates to FTC: Write rules to protect kids from harmful manipulative design onlineAt every turn, young people face tricks and traps to keep them online for hoursand sharing sensitive data.BOSTON, MA and WASHINGTON, DC – November 17, 2022 – A coalition of leading health and privacy advocates filed a petition today asking the Federal Trade Commission to promulgate a rule prohibiting online platforms from using unfair design features to manipulate children and teens into spending excessive time online. Twenty-one groups, led by Fairplay and the Center for Digital Democracy, said in their petition: “When minors go online, they are bombarded by widespread design features that have been carefully crafted and refined for the purpose of maximizing the time users spend online and activities users engage in.” They urged the FTC to establish rules of the road to establish when these practices cross the line into unlawful unfairness.The advocates’ petition details how the vast majority of apps, games, and services popular among minors generate revenue primarily via advertising, and many employ sophisticated techniques to cultivate lucrative long term relationships between minors and their brands. As a result, platforms use techniques like autoplay, endless scroll, and strategically timed advertisements to keep kids and teens online as much as possible– which is not in their best interests.The petition also details how manipulative design features on platforms like TikTok, Twitter, YouTube, Facebook, Instagram, and Snapchat undermine young people’s wellbeing. Excessive time online displaces sleep and physical activity, harming minors’ physical and mental health, growth, and academic performance. Features designed to maximize engagement also expose minors to potential predators and online bullies and age-inappropriate content, harm minors’ self-esteem, and aggravate risks of disordered eating and suicidality. The manipulative tactics also undermine children’s and teens’ privacy by encouraging the disclosure of massive amounts of sensitive user data.The advocates’ petition comes just months after California passed its Age Appropriate Design Code, a law requiring digital platforms to act in the best interests of children, and as momentum grows in Congress for the Kids and Online Safety Act and the Children and Teens’ Online Privacy Protection Act.The petition was drafted by the Communications and Technology Law Clinic at Georgetown University Law Center. Haley Hinkle, Policy Counsel, Fairplay:“The manipulative tactics described in this Petition that are deployed by social media platforms and apps popular with kids and teens are not only harmful to young people’s development– they’re unlawful. The FTC should exercise its authority to prohibit these unfair practices and send Big Tech a message that manipulating minors into handing over their time and data is not acceptable.”Katharina Kopp, Deputy Director, Center for Digital Democracy:“The hyper-personalized, data-driven advertising business model has hijacked our children’s lives. The design features of social media and games have been purposefully engineered to keep young people online longer and satisfy advertisers. It’s time for the FTC to put an end to these unfair and harmful practices. They should adopt safeguards that ensure platforms and publishers design their online content so that it places the well-being of young people ahead of the interests of marketers.”Jenny Radesky, MD, Associate Professor of Pediatrics, University of Michigan and Chair-elect, American Academy of Pediatrics Council on Communications and Media:“As a pediatrician, helping parents and teens navigate the increasingly complex digital landscape in a healthy way has become a core aspect of my work. If the digital environment is designed in a way that supports children’s healthy relationships with media, then it will be much easier for families to create boundaries that support children’s sleep, friendships, and safe exploration. However, this petition highlights how many platforms and games are designed in ways that actually do the opposite: they encourage prolonged time on devices, more social comparisons, and more monetization of attention. Kids and teens are telling us that these types of designs actually make their experiences with platforms and apps worse, not better. So we are asking federal regulators to help put safeguards in place to protect against the manipulation of children’s behavior and to instead prioritize their developmental needs.”Professor Laura Moy, Director, Communications & Technology Law Clinic at Georgetown Law, and counsel for Center for Digital Democracy and Fairplay:“As any parent or guardian can attest, games and social media apps keep driving kids and teens to spend more and more time online, in a way that neither minors nor their guardians can reasonably prevent. This is neither accidental nor innocuous—it's engineered and it's deeply harmful. The FTC must step in and set some boundaries to protect kids and teens. The FTC should clarify that the most harmful and widespread design features that manipulate users into maximizing time online, such as those employed widely by social media services and popular games, are unlawful when used on minors.” Groups signing on to the petition include: Center for Digital Democracy; Fairplay; Accountable Tech; American Academy of Pediatrics; Becca Schmill Foundation, Inc.; Berkeley Media Studies Group; C. Everett Koop Institute at Dartmouth; Center for Humane Technology; Children and Screens: Institute of Digital Media and Child Development; Eating Disorders Coalition; Electronic Privacy Information Center (EPIC); LookUp.live; Lynn's Warriors; Network for Public Education; Parent Coalition for Student Privacy; ParentsTogether Action; Protect Young Eyes; Public Citizen; Together for Girls; U.S. Public Interest Research Group; and UConn Rudd Center for Food Policy and Health.###ftc_engagement_petition_pr1.pdf, unfair_design_practices_petition_for_rulemaking_final_combined_filing.pdf

Government Needs to Step up its Efforts to Provide Meaningful and Effective Regulation.Under intensifying pressure from Congress and the public, top social media platforms popular with young people – Instagram, Snapchat, TikTok, Twitch, and YouTube – have launched dozens of new safety features for children and teens in the last year, according to a report from the Center for Digital Democracy (CDD). Researchers at CDD conducted an analysis of tech industry strategies to head off regulation in the wake of the 2021 Facebook whistleblower revelations and the rising tide of public criticism, Congressional hearings, and pressures from abroad. These companies have introduced a spate of new tools, default navigation systems, and AI software aimed at increasing safeguards against child sexual abuse material, problematic content, and disinformation, the report found. But tech platforms have been careful not to allow any new safety systems to interfere significantly with advertising practices and business models that target the lucrative youth demographic. As a consequence, while industry spokespersons tout their concerns for children, “their efforts to establish safeguards are, at best, fragmented and conflicted,” the report concludes.  “Most of the operations inside these social media companies remain hidden from public view, leaving many questions about how the various safety protocols and teen-friendly policies actually function.”  More attention should also be placed on advertisers, the report suggests, which have become a much more powerful and influential force in the tech industry in recent years. Researchers offer a detailed description of the industry’s “brand safety” system –  an “expanding infrastructure of specialized companies, technological tools, software systems, and global consortia that now operate at the heart of the digital economy, creating a highly sophisticated surveillance system that can determine instantaneously which content can be monetized and which cannot.” This system, which was set up to protect the advertisers from having their ads associated with problematic content, could do much more to ensure better protections for children. “The most effective way to ensure greater accountability and more meaningful transparency by the tech industry,” the authors argue, “is through stronger public policies.” Pointing out that protection of children online remains a strong bipartisan issue, researchers identify a number of current legislative vehicles and regulatory proceedings – including bills that are likely to be reintroduced in the next Congress – which could provide more comprehensive protections for young people, and rein in some of the immense power of the tech industry. “Tech policies in the U.S. have traditionally followed a narrow, piecemeal approach to addressing children’s needs in the online environment,” the authors note, “providing limited safeguards for only the youngest children, and failing to take into account the holistic nature of young peoples’ engagement with the digital media environment.” What is needed is a more integrated approach that protects privacy for both children and teens, along with safeguards that cover advertising, commercial surveillance, and child safety.   Finally, the report calls for a strategic campaign that brings together the diverse constituencies working on behalf of youth in the online media. “Because the impacts of digital technologies on children are so widespread, efforts should also be made to broaden the coalition of organizations that have traditionally fought for children’s interests in the digital media to include groups representing the environment, civil rights, health, education, and other key stakeholder communities.”

A coalition of more than 100 organizations is sending two letters to Congress urging action. A letter addressed to Senate Majority Leader Chuck Schumer and Minority Leader Mitch McConnell, from 145 organizations, urges them to advance KOSA and COPPA to full Senate votes. A letter addressed to House Energy and Commerce Chair Frank Pallone and Ranking Member Cathy McMorris Rodgers, from 158 organizations, urges them to introduce a House companion bill to KOSA. The advocates state in the letter to the Senate: “The enormity of the youth mental health crisis needs to be addressed as the very real harms of social media are impacting our children today. Taken together, the Kids Online Safety Act and the Children and Teens’ Online Privacy Protection Act would prevent online platforms from exploiting young users’ developmental vulnerabilities and targeting them in unfair and harmful ways.” kosa_coppa_senate_leadership_letter_final_9.12.22-1.pdf, eandc_leadership_kosa_letter_final_9.12.22-1.pdf, kosa_coppa_rally_press_release_embargo_to_9_13.pdf