program areas Digital Youth

Statement of Kathryn C Montgomery, Ph.D. Professor, School of Communication, American University Senior Consultant, Center for Digital Democracy December 4, 2017 In its first formal move to enter the children’s digital marketplace, Facebook has taken a responsible approach to this sensitive age group. It has created a “walled garden” messenger service designed exclusively for younger children; established strong parental controls; kept the service free of advertising; and restricted the use of many data collection and targeting practices that are employed routinely in its other services. The Children’s Online Privacy Protection Act (COPPA) – which we helped pass in 1998, and which was updated in 2012 – has established a strong framework for protecting children 12 and under from unfair data collection and targeting. However, additional safeguards are necessary to protect young people from powerful new forms of commercial surveillance in the Big Data and Internet-of-things era. By designing an ad-free and safe environment for children, Facebook is playing a leadership role in developing responsible corporate practices that could be the basis for industry-wide guidelines. But it is too early to understand fully how young people’s engagement with this new generation of digital interactive platforms will impact their psychosocial development. All stakeholders—including health professionals, educators, scholars, advocates, policymakers, and corporations — will need to monitor very closely how these services evolve. ---

Sanjay Nazerali, Chief Strategist of Carat, a global media market leader in digital media, writes about how YouTube influencers are rewriting the marketing rulebook. Working in strategy at one of the world’s largest media agencies, I’ve witnessed countless pitches about influencer marketing and the growing power of creators. With engaged audiences in the millions and passionate fans hungry for content, YouTube creators are already an established channel for brands looking to run ads. In fact, Carat’s latest analysis suggests online video investment (including YouTube) can be increased by 3X compared to planned level. But increasingly, these influencers are also becoming attractive partners for deeper collaborations. Clients are initially enthusiastic, assuming this is the digital age’s answer to celebrity marketing and endorsement. Then the thorny business questions arise, such as: So what’s it actually doing for my brand? Do I do an endorsement or product placement—or what? Isn’t it just for millennials, beauty brands, and makeup tutorials? These have always been tough questions to answer. Even though almost everyone has been jumping on the influencer bandwagon, few understand what “influence” really is or how it works. Until now. Celebrity marketing and influencer marketing offer fundamentally different benefits for brands. Together with YouTube and Nielsen, my team analyzed the results of hundreds of brand and creator videos in the U.S. and the U.K to understand the impact of influencers for brands. It’s a critical first step in establishing a business-led rulebook for this new world—and it’s already changing how I approach my own plans. 1. Influencers are not the same as celebrities Influencers, however vast their reach, are absolutely not “today’s celebrities,” and celebrity marketing and influencer marketing offer fundamentally different benefits for brands. For instance, we found that celebrities are more effective at driving recall than creators (84% versus 73%). Given that a celebrity’s job is to be famous and memorable, that makes sense. Where YouTube creators really start to gain the upper hand is in deeper brand involvement. Brand familiarity is a good example. If we want to get an audience to really understand us, our work, our values, or our products, then collaborations with YouTube creators are 4X more effective at driving lift in brand familiarity than those with celebrities. When it comes to purchase intent, it’s an even match: our research found that influencers were just as likely as celebrities to drive buying decisions. Influencer marketing appears to play a fundamentally more pragmatic role. Why? My hunch is that it’s because fans feel very connected to the YouTubers they love. The best creators have formed authentic bonds with their fans, which means fans trust what they have to say, and turn to them for brand and product recommendations. 2. It’s not just a ‘beauty’ thing Beauty brands were one of the first to team up with influencers, and creators have established a huge presence among the YouTube beauty community. About 86% of the top 200 beauty videos on YouTube were made by creators rather than professionals or brands. But what’s interesting about our findings is just how far influencers stretch beyond the beauty category. We tested nine additional categories, including auto, alcohol, snacks, and toys. Across all nine categories, working with influencers leads to lifts in brand metrics, from familiarity to affinity to recommendation. In some categories, such as snacks and alcohol, they can have even more impact, driving significantly higher than average purchase intent. So the idea that influencer marketing is purely for young people who are looking at fashion and beauty brands simply isn’t true. 3. The ‘how’ matters as much as the ‘who’ Celebrity marketing has historically focused on endorsement, sponsorship, and product placement. Influencer marketing has developed far more options, and it’s important to understand which of these work best—and for which marketing goals. Deep thematic integrations with creators stand out as driving the highest results for brands. These are more involved integrations where the influencer plays a role in creating a piece of content – such as a demo – with the brand. It’s far deeper than product placement and it works more effectively. While there were many consistencies across categories, we also saw some nuances, which are important for clients to understand. We found that simpler brand integrations, like a product endorsement or just featuring a creator in an ad, also showed positive results for brand affinity in all categories tested. Of course, deep collaborations can be more than some brands are ready for. For some objectives and categories, simply running their own ads on YouTube creator content will still be the easiest and most effective way to tap into the power of these influencers. 4. Don’t lose sight of why people love YouTubers We often assume that the right influencer is either an aspirational version of our target audience or that they’re just like celebrities. Neither of these assumptions is correct, and it’s perhaps here that celebrity and influencer marketing differ the most. Whereas celebrities need to be trendy and stylish, consumers expect creators to be friendly, funny, and, yes, sometimes irreverent. Irreverence is interesting, because it drives credibility. Irreverence strongly suggests independence, and it’s this that builds trust. It can also be incredibly valuable for brands. If a creator usually ridicules things they don’t like, you can be sure that when they praise something, they mean it. Humour is also interesting, because it reflects a sense of community. YouTube helps forge a special relationship between followers and influencers, one that reflects a sense of co-ownership. This familiarity creates a degree of intimacy that makes the use of humour seem much more natural than it would do with celebrities. This is probably also why we see celebrities, such as Dwayne Johnson, increase their influencer scores when they get really active on YouTube. Prioritization and strength of attributes by gen X and gen Y associated with celebrities are different to creators. --- For the full article, visit http://bit.ly/2z6MHng (link is external) Is it Hype? Or is it Real? Decoding the Influence of YouTube Influencers Read more at http://newyork.advertisingweek.com/CALENDAR/-google-seminar-2017-09-26-1... (link is external)

Personal health wearable devices that consumers are using to monitor their heart rates, sleep patterns, calories, and even stress levels raise new privacy and security risks, according to a report released today by researchers at American University and the Center for Digital Democracy. Watches, fitness bands, and so-called “smart” clothing, linked to apps and mobile devices, are part of a growing “connected-health” system in the U.S., promising to provide people with more efficient ways to manage their own health. But while consumers may think that federal laws will protect their personal health information collected by wearables, the report found that the weak and fragmented health-privacy regulatory system fails to provide adequate safeguards. The report, Health Wearable Devices in the Big Data Era: Ensuring Privacy, Security, and Consumer Protection, provides an overview and analysis of the major features, key players, and trends that are shaping the new consumer-wearable and connected-health marketplace.“Many of these devices are already being integrated into a growing Big Data digital-health and marketing ecosystem, which is focused on gathering and monetizing personal and health data in order to influence consumer behavior,” the report explains. As the use of these devices becomes more widespread, and as their functionalities become increasingly sophisticated, “the extent and nature of data collection will be unprecedented.”The report documents a number of current digital-health marketing practices that threaten the privacy of consumer health information, including “condition targeting,” “look-alike modeling,” predictive analytics, “scoring,” and the real-time buying and selling of individual consumers. The technology of wearable devices makes them particularly powerful tools for data collection and digital marketing. For example, smartphones and other mobile devices already provide access to users’ location information, enabling marketers to target individuals wherever they are, based on analyses of “visitation patterns” and a host of other behavioral and demographic data.The report also explains how an emerging set of techniques and Big-Data practices are being developed to harness the unique capabilities of wearables—such as biosensors that track bodily functions, and “haptic technology” that enables users to “feel” actual body sensations. Pharmaceutical companies are poised to be among the major beneficiaries of wearable marketing.The report offers suggestions for how government, industry, philanthropy, nonprofit organizations, and academic institutions can work together to develop a comprehensive approach to health privacy and consumer protection in the era of Big Data and the Internet of Things. These include:Clear, enforceable standards for both the collection and use of information;Formal processes for assessing the benefits and risks of data use; andStronger regulation of direct-to-consumer marketing by pharmaceutical companies.“The connected-health system is still in an early, fluid stage of development,” explained Kathryn C. Montgomery, PhD, professor at American University and a co-author of the report. “There is an urgent need to build meaningful, effective, and enforceable safeguards into its foundation.”Such efforts “will require moving beyond the traditional focus on protecting individual privacy, and extending safeguards to cover a range of broader societal goals, such as ensuring fairness, preventing discrimination, and promoting equity,” the report says.“In the wake of the recent election, the United States is on the eve of a major public debate over the future of its health-care system,” the report notes. “The potential of personal digital devices to reduce health-care spending will likely play an important role,” as lawmakers deliberate the fate of the Affordable Care Act. However, unless there are adequate regulatory safeguards in place, “consumers and patients could face serious risks to their privacy and security, and also be subjected to discrimination and other harms.”“Americans now face a growing loss of their most sensitive information, as their health data are collected and analyzed on a continuous basis, combined with information about their finances, ethnicity, location, and online and off-line behaviors,” said Jeff Chester, Executive Director of the Center for Digital Democracy, and another co-author of the report. “Policy makers must act decisively to protect consumers in today’s Big Data era.”The Robert Wood Johnson Foundation provided funding for the report.The three authors of the report —Kathryn Montgomery, Jeff Chester, and Katharina Kopp—have played a leading role on digital privacy issues, and were responsible for the campaign during the 1990s that led to enactment by Congress of the Children’s Online Privacy Protection Act (COPPA).---Full report attached.

WASHINGTON, D.C. – Advocates called today on the Federal Communications Commission (FCC) to reject an effort by major media companies to eliminate or weaken important rules for children’s television. The National Association of Broadcasters, Internet and Television Association (NCTA), CBS, Disney, Fox, Univision, and others have asked the FCC to significantly reduce advertising limits on children’s programming. Industry commenters also urged the FCC to reconsider rules that require broadcasters to provide quality educational programming as part of their obligation to serve the public interest. In comments filed today, Campaign for a Commercial-Free Childhood and the Center for Digital Democracy called on the FCC to reject industry proposals to repeal or modify the current rules. “The Trump Administration and the FCC should stand up for the rights of children and parents and reject this crass campaign by the broadcast lobby,” said Jeff Chester, executive director of the Center for Digital Democracy. “The broadcast industry receives billions of dollars in benefits from its free use of public resources, including invaluable rights to the airwaves. It is unconscionable that TV stations and networks want to kill off one of their few remaining obligations to the public.” In April, the FCC issued a public notice on its “Modernization of Media Regulation Initiative,” asking for suggestions about which of the FCC’s media-related rules should be modified or repealed. Media companies replied with a deregulation wish list that would allow them to use kids’ television programming to market directly to children. The major networks urged the FCC to relax its rules prohibiting product integration and product placement on kids’ shows, arguing that YouTube and other child-directed online services are not subject to those restrictions. Advocates responded by pointing out that internet and mobile providers are simply ignoring longstanding children’s media principles, which are based on child development, and that a lack of online regulation is not a good reason for the FCC to eliminate important safeguards for the millions of children who watch traditional TV. “It is extremely disappointing that broadcasters want to join the race to the bottom when it comes to exploiting children’s developmental vulnerabilities for profit,” said Josh Golin, executive director of the Campaign for a Commercial-Free Childhood. “Media companies want to gut longstanding safeguards because young people an incredibly lucrative market for advertisers. But research demonstrates that children are particularly vulnerable to marketing and benefit from rules that require ad limits and separation of programming and commercial content.” Advocates also oppose a request by the Internet and Television Association to repeal an FCC rule known as the “website display rule.” The FCC adopted this rule in 2004 to prohibit advertisers from engaging in “host-selling” to children, which the transition to digital broadcasting could otherwise allow. Angela J. Campbell, director of the Institute for Public Representation at Georgetown and counsel to some of the advocates, called the effort to repeal this rule disingenuous. “The media companies say the website display rule is unnecessary because television has rarely been used to interact and target advertising to children,” she said. “But at the same time, these companies engaging in a practice known as ‘programmatic marketing,’ which offers advertisers the ability to target ads to specific viewers of cable and broadcast television programming.” In addition, advocates oppose efforts by media companies to be relieved of their public interest obligation to provide educational programming for children, and to produce public reports to help the FCC determine whether that programming meets the obligations laid out in the Children’s Television Act. “The television industry made a commitment to serve the nation’s children by providing quality educational programs,” explained Professor Kathryn Montgomery of American University, who led the effort to strengthen the FCC’s rules on the Children’s Television Act. “However, broadcasters failed to live up to these minimal obligations and the FCC has been irresponsible in allowing the industry to evade one of its only remaining public interest requirements. Rather than considering elimination of these rules, the FCC (and Congress) should conduct an investigation into TV programming and advertising practices directed at children.” ---- The comments can be read via the attached PDF file below.

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Facebook should immediately release all documents describing how it collected and analyzed psychological information it recently (link is external) collected about its youngest users, some as young as 14, and college students, Public Citizen and a coalition of 25 groups said in a letter (link is external) to the corporation today. The groups are concerned about how this information might have been used or may be used in the future by marketers and others to take advantage of young people’s emotions, all without users’ knowledge. Marketing companies and Facebook have secretly moved to tap into teens’ emotions and developmental vulnerabilities strictly for profit, the letter says. The groups want to know how the data was used, when it was used, how many users were impacted and the names of the companies that received the data. “What began as a way for college students to keep in touch has morphed into a platform for brand-saturated marketing and psychological manipulation,” said Kristen Strader, campaign coordinator for Public Citizen’s Commercial Alert campaign. “It is incumbent upon Facebook as a cultural leader to protect, not exploit, the privacy of young people, especially when their vulnerable emotions are involved.” According to The Australian (link is external) newspaper, Facebook presented research to one of its advertisers that shows it collects sensitive data regarding young users’ emotions and “mood shifts.” The research detailed how Facebook can analyze sensitive user data in real time to determine how young users are communicating emotion, and at which points during the week they are doing so, the letter continued. Facebook’s research was conducted without users’ knowledge, which raises ethical concerns. “Because Facebook plays such a powerful role in the lives of teens, it must adopt a policy that respects and protects them,” said Dr. Kathryn Montgomery, professor of communication at American University and a consultant to the Center for Digital Democracy. “This should include not only strong safeguards for its advertising and data practices, but also clear limits on the kinds of research it conducts for marketing purposes. Under no circumstances should marketers be using emotional states, stress levels, biometric information or other highly sensitive data to target users. And this should apply to both young people and adults.” “Facebook needs to come clean and publicly release the full internal document, reported in The Australian, describing how Facebook collected and analyzed psychological information on high school students, college students and young users, said Finn Lützow-Holm Myrstad, European Union co-chair of the Transatlantic Consumer Dialogue. “The burden of proof is on Facebook to document publicly that they don’t collect and use such information. We are concerned that companies don’t overreach and abuse their users’ fundamental right to privacy and data protection.” The public, its users and elected officials have a right to know how pervasive this research was, who was affected and how the company will ensure it does not occur again, the groups said. The only way to fully address those concerns is to publicly release the internal document and related materials, accompanied by a more detailed explanation from Facebook of what was intended, what happened and the company’s actual practices, the letter says. —30— --- See full PDF of letter to Facebook below.