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CDD asks Court to Require FTC Make Public Information on âSafe Harborâ Programs for COPPA (Childrenâs Online Privacy Protection Act)
The Center for Digital Democracy (CDD), in its ongoing efforts to monitor the Federal Trade Commissionâs enforcement of the Childrenâs Online Privacy Protection Act (COPPA), has filed a motion in the U.S. District Court of the District of Columbia challenging the FTCâs refusal to release important COPPA documentation. The case involves seven âsafe harborâ programs, such as KidSAFE and TRUSTe, approved by the FTC to handle website compliance with COPPA regulations. CDD originally made its request in July 2014, under the Freedom of Information Act, seeking access to annual reports filed with the FTC by safe harbor organizations, as required by COPPA. In light of the commissionâs failure to respond to that request within FOIAâs statutory time limit, CDD initiated the current legal proceeding in December 2014. Two months later, the FTC finally responded to CDDâs FOIA request, releasing heavily redacted annual reports amounting to less than half of CDDâs original request.As CDDâs court filing makes clear, the FTC has been overzealous in protecting the self-interest of the private Safe Harbor programs. CDDâs predecessor, the Center for Media Education, spearheaded the movement that led to the passage of COPPA in 1998. The regulation applies primarily to commercial websites that target children under 13, limiting the collection of personal information, providing a mechanism for parental involvement, and placing obligations on companies for adequate disclosure and protection of data. More recently, CDD led a coalition of child advocates, privacy groups, and health experts that successfully pressed for a revised set of regulations that update and clarify COPPAâs basic safeguards. These new regulations, which became effective in 2013, add new protections specifically designed to address a wide range practices on social media, mobile, and other platforms. Without the diligent oversight of the FTC, however, COPPA regulations will mean little in the rapidly evolving online marketplace. As it awaits a favorable ruling from the District Court, CDD remains committed to ensuring that COPPA is fully and fairly enforced. See the filed memo attached below. -
Blog
How YouTube, Big Data and Big Brands Mean Trouble For Kids and Parents
The motivation for big tech is to mold this generation of youth into super-consumers.
By Jeff Chester (link is external) / AlterNet (link is external) April 6, 2015 There is a âdigital gold rushâ underway to cash in on young peopleâs passion for interactive media. Google and other media (link is external) and ad companies are working to transform kidsâ clicks and views into bundles of cash and burgeoning brand loyalty. While TV still dominates a great deal of kidsâ media viewing, they are also consuming content (often simultaneously) on mobile devices, tablets, and through streaming or video-on-demand services. In February, Google (link is external) launched its YouTube Kids app for children five and under; Disney acquired leading youth-focused online video producer Maker Studios (link is external) last year in a more than $500 million deal, giving it control of âthe largest content network on YouTubeâ; Viacomâs Cartoon Network (CN) now offers CNâs âAnything,â providing mobile phone-friendly âmicroâ content and promising to serve a ânetwork of devices giving a network of experiences to a network of fansâ; and Amazon, Netflix, and others are sending more âkid targetedâ streaming video-on-demand programming. But unlike broadcast and cable TV, where there is at least a handful of FCC regulations that prevent some of the worst practices perfected by advertisers for targeting kids, the online world is mostly a regulatory-free zone when it comes to digital marketing. Advocates and child-health experts fought a long campaign, from the 1970âs to the 1990âs, to ensure that TV didnât take unfair advantage of how kids relate to advertisingâso that shows werenât simply âprogram-length commercialsâ for toys, or that the âhostâ or star of a programâsuch as a cartoon characterâdidnât also pitch products at the same time. There were also modest limits in how many ads could appear in so-called âkidvidâ programming. These rules reflected research on childrenâs development and their inability to fully comprehend the nature of advertising. The FCC (link is external) policies embraced an important principle: children were to be treated differently than adults when it came to TV advertising. Such safeguards are even more important in the digital era, when sophisticated advertising techniques gather and analyze data on everything an individual does, and incorporate an array of powerful interactive features on mobile devices and PCs that have been designed to get results. Parents and others who care about children should be forewarned: For Google, Facebook, media companies like Nickelodeon, toy companies, and junk food marketers, the Internet is a medium whose primary focus is to help brand advertisers turn young people into fans, âinfluencersâ (to spread the word via social media), and buyers of products. Although children benefit from using educational apps, and have greater access to more diverse entertainment and other content, the motivation really at work is to mold this generation of youth into super-consumers, encouraged to engage in a never-ending buying cycle of goods and services. Children (link is external) are now a key target for Googleâs âmonetizationâ strategies, helping the company cash in from the sales of toys, apps, junk food, and other products. (So-called âtweensâ in the U.S. alone are said to influence (link is external) some $200 billion a year in spending, including $43 billion of their own money.) With Googleâs overall revenue growth slowing, with Facebook aggressively seeking to displace it as the global digital advertising leader, and with consumers flocking to mobile phones (instead of PCs) to view videos and use apps, kidsâwhich were one of the only consumer groups not formally targeted by Google until nowâare viewed as an essential new market to conquer. In February, Google unveiled a new advertiser-supported âYouTube Kidsâ app, its first âproduct built from the ground up with little ones in mind.â Googleâs YouTube Kids âproduct managerâ claimed that âthe app makes it safer and easier for children to find videos on topics they want to explore.â Google also promised that ads âthat arenât kid-appropriate donât surface.â But Googleâs YouTube Kids (link is external) is filled with ads disguised as programming and product pitches that violate rules that broadcast and cable TV channels have to follow. A coalition of consumer, privacy, and childrenâs advocacy groups urged the FTC to investigate Googleâs new YouTube Kids app, as well as how the company targets older children on YouTube itself. (Six (link is external) of YouTubeâs leading channels are âaimed at children.â) Google wants to place even the youngest kids inside its powerful marketing apparatus, making sure they will help the company generate much-needed profits as they grew older. It is encouraging brands to take advantage of how young people are engaging in a âmulti-screen experience,â including watching video on smart phones, and how YouTube combines the attributes of video service and social networking. Google explains (link is external) that YouTube takes the most powerful medium for connecting with the heart and mindâvideoâand elevates it from a one-way communication to a two-way experience by inviting brands and consumers alike to connect, curate, create and form community ⌠. On YouTube, brands have the unparalleled opportunity to connect with their most valuable audience and the creative freedom to do so in the most compelling way. The reward for the marketer is a fanbase moved not only emotionally, but also literally, to purchase, comment, share and advocate for that brand. In short, YouTube moves people to choose your brand. As an article on the launch of YouTube Kids explained, âIf YouTube can earn the trust of parents and hook (link is external) a new group at an even earlier age, then thatâs tapping a whole new market of users that will literally grow up with the serviceâand use it for a much longer portion of their lives.â While appearing as a distribution service for many programmers, independent and professional, YouTube is a key part of an incredibly sophisticated, elaborate, and highly powerful global marketing apparatus. Google executives recently pledged that they are âlistening to brandsâ and taking âactionâ to help make YouTube a more effective platform to help accomplish their goals. YouTube: âone of the biggest Big Data projects in the worldâ YouTube incorporates (link is external) all of Googleâs expertise in gathering and analyzing consumer information, so a user, even a young one, can be effectively targeted with marketing. YouTube, it explains, âis one of the biggest Big Data projects in the world.â âAt YouTube, data drives the way we make decisions,â including to help its advertisers âget closer to the holy grail of precision targeting.â YouTube, explains the company, has âone of the worldâs richest datasets,â which it combines with âGoogleâs cutting-edge technologyâ to âtransform insights into real-world products.â YouTube continually researches and develops ways to measure and analyze how ads can work more effectively; it identifies ânew algorithms and methods for optimizing ads,â âresearches new ways for modeling end user behavior,â and more. Its data fuel YouTubeâs ârecommendation systems,â and the company is now âpushing the boundaries of science and engineeringâ to make its home page deliver more revenue. It offers its users, including children, ârecommended videosâ as well as other products that help its advertisers. Through machine learning about us, including analyzing our data, Google plans to further strengthen how it can âintroduce users to areas of their interest that many did not realize YouTube had.â YouTube is now working to âbuild the next generation game-console based TV experience with YouTube video content,â which will deliver âa compelling lean back experience with monetization and e-commerce offeringsâ (including âpay-per streamâ and ad content), as well as through partnerships that âintegrateâ its content. Generating revenues by attracting and targeting gamers is a key part of YouTubeâs marketing-to-youth strategy. It is also positioning YouTube to be a key part of digitally connected âLiving Roomâ devices, including âgame consoles, smart TVâs, set-top boxesâ to âdrive distribution and user engagement.â We âput your brand in their handâ Through its âbrand channelsâââa 24/7 broadcast center where customers can watch, share and love your brandââYouTube helps advertisers like Red Bull and Walmart âenergizeâ its customers. These channels can be specially configured to work well with mobile devices, explains Google, so marketers (link is external) can âput your brand in their hand.â Google also offers a âCustom Brand Channelâ on YouTube, âthe highest level of brand channel customization,â which incorporates special âinteractive applicationsâ designed to promote the âbrandingâ experience more effectively. Last year, as part of its ongoing effort to work more closely with leading advertisers, Google also unveiled its âPartner Selectâ program, which helps its clients take advantage of its advanced data-targeting platform to run ads on its top-ranked video programming. Google is working to have YouTube play a key role erasing whatâs left of the boundaries that have separated advertising and content. Through what it calls âcontent marketing,â YouTube promises to help its advertisers take advantage of our âshortening attention spansâ to positively respond to a brandâs message, explaining that âIn a world of shortening attention spans and increasing options, advertising is undergoing a sea change. More and more, ads are becoming content that people choose to watch. ⌠[W]e use the tools and know-how developed by a generation of YouTube content creators to help brands develop ads that will resonate with todayâs consumers.â As a leader in using mobile phones to target individuals based on their actual location, Google is also in the forefront of delivering its content on smart phones and similar devices, boasting that âviewing video on smartphones is far less distracted than it is on TV.â YouTube: âPrecision Targeting at Scaleâ To help its advertisers, YouTube provides âprecision targeting at scaleâ thatleverages (link is external) âthe sight, sound and motion of video, the most persuasive ad format every evented.â Google claims that its âtargeting tools are so preciseâ marketers âcan show your ad to folks around your corner or to anyone around the world.â One can target by age, gender, zip code, language, interest, and can âretargetâ someone whose data have been (largely secretly) collected when they were on YouTube or other sites. Google offers advertisers a formidable arsenal of â3rd Party Audience Dataâ that can incorporate details on oneâs finances, buying behavior, and many other personal details. Now reaching one billion people worldwide, YouTube identifies Hispanics, teens, those âhard to reach,â as well as adult men and women as key targets; it notes, for example, that â54% of all teensâ and â59% of all Hispanicsâ use it. (Among the âfactsâ on Hispanics it lists for advertisers is that â76% currently own a petâ and â58% are grocery decision makers in their household.â) YouTube also plays a direct role helping key advertisers achieve their goals, including through its âin-house creative teamâ (which it calls âThe ZOOâ) that âcan unleash the true power of your message with a custom campaign.â YouTubeâs âBrand Nirvanaâ Promotes Junk Food to Kids Google has been helping Mondelez, Pepsi, and other fast-food marketers push their productsâdespite concerns about the global obesity epidemicâespecially on young people. Last year, Mondelez signed a deal with Google that featured the candy (link is external) and snack company (Oreo, etc.) making a commitment to âaccelerateâ its investment in online video. The pact involved the use of Googleâs advanced data-driven targeting system (known as âprogrammatic buyingâ) and the development of more âbranded content.â Google and Mondelez are âpartnering on content pilots through YouTubeâs Brand Partner Program ⌠[to produce] low-cost video content featuring influential digital stars with Sour Patch Kids in the U.S.â Mondelezâs YouTube channel for Oreos features an array of ads dressed up as games, in English and Spanish, which is typical of Googleâs use of video to promote junk food products using the full power of its platform. Fast-food companies, including such brands as Coca-Cola, Mars, Mondelez, Wendyâs, and Post cereal, are also using advanced analytics on YouTube viewing to help refine their targeting strategies. Frank Cooper, Pepsiâs chief marketing officer, was a keynote speaker at YouTubeâs âBrandcastâ 2014 event. In announcing that Pepsi has increased its spending for YouTube services by 50 percent over the last year, Cooper noted that âwe live in a world where visual content in the digital space is the new center of gravity for pop culture,â and being on YouTube and related digital applications enables Pepsi (link is external) to be part of a conversation that is âdriving culture.â When people share âyour content with their friends,â he noted, it is âbrand nirvana.â YouTube as Toy Promotion Central Google is positioning YouTube (link is external) to be a central place for children to learn about toys they want their parents or family to buy. As one toy business analyst explained, âItâs a totally new way of advertising. [The YouTube channels] are becoming more and more important.â Although Googleâs terms of service (ToS (link is external)) for YouTube requires users to be 13 and older, itâs clear that it is targeting kidsâand violating its own policyâin order to profit from the childrenâs market. Its ToS states that âthe Service is not intended for children under 13. If you are under 13 years of age, then please do not use the Service. There are lots of other great web sites for you. Talk to your parents about what sites are appropriate for you.â Yet despite its own ToS banning children from signing up, YouTube is clearly targeting kids. For example, âFunToyzCollector (link is external),â which describes itself as âall about kid-friendly videos for toddlers, babies, infants and pre-school children,â recently placed first in views among all the YouTube channels (517.3 million). The channel engages in âunboxingâ toys, an increasingly sought after YouTube genre that provides viewers with a âvirtual tourâ of kids products, such as âSofia the First Balloon Tea Party 2-in-1 Playset with Disney Frozen Princess Anna Elsa of Arendelle.â Very popular with young kids in the U.S., the YouTube ad-supported channel made its owner an estimated $4.9 million last year. Kids either find or are shown these channels as they search for new toys to buy or to receive as presents. âDisneyCarToys (link is external),â âa fun kid friendly toy channelâ produced by Disney subsidiary Maker Studios, is another example of how Google profits by permitting the targeting of children. The channel is one of five toy-related YouTube channels that Disney acquired (link is external) in 2014, including âHobbyKidsTV, ToyReviewToys, AllToyCollector, and TheEngineeringFamily.â These popular âtop 40 toy channels worldwide,â which integrate Disneyâs characters and brands into the programming content, are now part of Disneyâs âmerchandisingâ strategy, which will include more brand tie-ins and advertising. Maker Studios itself has a major kids marketing presence on YouTube. It describes its âCartoontium (link is external)â set of programs as âthe place to find all the best kidâs entertainment on YouTube!â One of its channels is called âMessy Painting in the Dark-Neon Arcade,â where âToys, games and financial support [is] provided by Hasbro.â Other Cartoonium programming features âclassic episodes of Care Bears and Strawberry Shortcake.â âStrawberry Shortcakeâ and other programming include ads for toys (and some of these shows are also on the YouTube Kids app). One reason Disney acquired Maker, explained CEO Bob Iger, was to reap its âgreat access to data and algorithms,â which are gathered from billions of views collected through its 55,000 YouTube channels. Another kidsâ toyâfocused YouTube service is also partnering with the Disney/Maker empire. âEvanTubeHD (link is external),â involving two young children (eight and five years old) and their father, âboasts more than a billion views acrossâ three channels. The two children âreview and play with the most popular kids toys currently on shelves.â As an analyst explained why toy companies are enthusiastically seeking out relationships with kid reviewers online, âKids trust other kids more so than they would an adult.â Maker has a broad range of marketing services it offers brands (link is external) and advertisers, including âcustom pre-rollâ ads (the short spots that run before a YouTube or other video content starts); channel targeting (âintegrate your brand message natively into our top performing channelsâ); and sponsorships (âMore than just a logo, our unique custom sponsorships allow you to connect with our forward leaning and deeply engaged audiencesâ). Maker touts its strong alliance of partners, including its âcustom solutions to the world's best brandsâ and âeffective and hyper-targeted media solutions.â Partners include Mattel, Pepsi, Warner Bros, and parent Disney. It also works with the leading ad agencies that represent major global brands âto create unique programs across our programming and talent.â In another example of how Google fails to protect children, it allows Disney to encourage its young viewers to connect to them using Facebook, Twitter and Instagramâdespite these sites requiring users to be 13 years or older. So eager is Google to reap profits, it appears purposely to ignore how toy companies are establishing nothing more than 24/7 virtual ad channels on YouTube. For example, Spin Master, a âtop-fiveâ toy company, has created a âkid centric YouTube channel dubbed SpindoTV (link is external), aimed at children 6-11. Its shows are based on its toy line-up, including âSick Bricksâ and âBeat the Parentsâ board game. Many of its shows are a part of Googleâs new YouTube Kids app. According to a Spin Master executive, âWe know from our research that these kids are already on YouTube in massive numbers.â YouTube, of course, is just one method Google uses to help it reach and monetize young people. It is also âbuilding successful apps and gamesâ for its âGoogle Play for Education and Kids vertical,â helping developers create âcommercially viable offerings to educators and students, parents and kids.â The popularity of YouTube among children has triggered a âmust-have-the-video-networkâ buying strategy from companies targeting the youth market worldwide. Marketers researching youth know that kids are using YouTube as a search engine because it includes pictures, videos, and other audio-visual material. Itâs also âeasy to navigateâ for children, with reports that âkids who are into watching TV episodes on YouTubeâ like to see other episodes and ârecommended videosâ on the sidebar. More critically, digital market researchers studying children have identified YouTube as providing an important social and creative outlet for tweens, and finding cool YouTube videos to share with others is a form of social capital. ⌠[T]weens most frequently share cool videos when hanging out (in person) with their friends and family. ⌠[W]e call this phenomenon clustersharing. ⌠[I]t speaks more to their desire to physically experience videos with othersâto see, to feel and to share that experience, including their thoughts and emotions. The same researchers advise marketers to take advantage of the âclustersharing (link is external)â concept, and encourage ways to âenhance that in-person, social experience. Using ad content (like a group game) or finding a way to alleviate the agonizing âliveâ wait of a 15-second pre-roll between each video presents âan opportunity to enrich your brand experience with this very engaged audience.â Tracking our âConsumer Journeyâ Google is in the forefront of digital marketing companies promising to help its clients influence and âmeasureâ what it calls the âcustomer journey.â It views itself as helping them analyze and place each consumer on a continuous âpath-to-purchase (link is external)â cycle, tracking us wherever we go, and using its resources to have us shop âuntil we dropââonline and off. Among the benefits Google promises its advertisers, for example, is that they will be able to identify and âvalueâ their âbest customers,â and âdistinguish the whales from the wasted energy.â (âWhalesâ is a marketing industry term describing a big spender; âwasteâ is an ad term for a consumer deemed not valuable.) YouTube conducts research (link is external) to document how its advertisers positively impact our ârecallâ of various brand commercial messages. Googleâs DoubleClick division, which uses data to determine the impact of video ads, offers advertisers the latest ways they can âverifyâ whether a person actually views a video ad on YouTube. To help its largest advertising clients measure how we respond to Googleâs interactive marketing services, the company is now working with Nielsen and comScore, two of the leading global companies that assess consumer interaction with ads, including on YouTube. There are other companies also helping marketers analyze YouTube data. For example, Outriggerâs âOpenSlate (link is external)â platform âingests, analyses and scores more than 220,000 YouTube channels on measures of engagement, consistency, influence, momentum and ad effectiveness.â (It now is up to 250,000 channels.) It âsupplements YouTube data on more than 70 million videos with data from social media and proprietary demographic data. Our platform consistently incorporates brand advertising performance data to further develop video and channel level profiles.â Through its information, brand advertisers can identify âthe highest-quality inventory on YouTube,â and then target them using a variety of Big Data tactics. (âInventory,â as used by the online marketing industry, can either refer to individual users or programming content. Kids and teens are seen as highly valuable âinventory.â) Time for Regulatory Action Against Google to Protect Kids Google, as the dominant digital marketing company, has raised numerous concerns about its corporate practices, including from privacy regulators, civil liberties advocates, and competition regulators from around the world. (The company has led an anti-privacy-regulation agenda in both the U.S. and EU, to ensure that the flow of personal data that makes its interactive marketing system run will never end.) Its latest move to better monetize children through YouTube Kids is the first of what will be a succession of profit-generating ventures that help transform kidsâ lives into a never-ending commercial. Even Facebook, which expressed interest in targeting children 13 and younger, has not yet directly entered the kids market. Googleâs brazen move to cash in on our kids will likely spur Facebook to jettison any reticence to include them on its social network. After all, why should Google gain all the profits from this new, lucrative, and influential audience? Beyond federal and state investigations into Googleâs brazen targeting of children on YouTube, whatâs needed now are new policies that ensure young people arenât unfairly treated by digital marketers. This includes rules that donât leave children and teens vulnerable to digital marketing practices and also better protect their privacy. For example, Google is at the forefront of companies using what is called âimmersiveâ media, to make sure brandsâincluding on YouTubeâcan âgrabâ our attention. All of the data gathered from our use of mobile phones, social media, and online video feed so-called âprofilesâ that are used to target us for advertisingâincreasingly regardless of location (think of a mobile discount coupon from a nearby fast food outlet appearing on childrenâs phones as they come out of school) and in real-time (right as you are in the store cereal or toy aisle). These practices are highly questionable when targeting adults, let alone young people. Companies like Google should develop their own policies that actually protect and empower young peopleânot just turn them into the latest profit center. A global leader like Google, with immense profits, should only be offering kids commercial- (and data targeting-) free content. It shouldnât be helping junk food and toy companies take advantage of kids to sell them products that donât promote their development and health. It is doubtful, however, that Google will change course. It is, after all, primarily an advertising company whose allegiance is to the biggest brands and the marketing industry. Itâs time for activist shareholders of Google and other companies to press for the adoption of new corporate policies that protect young people in the digital age. Parents will have to decide whether Googleâs corporate culture, focused as it is on promoting marketing to young kids, is incompatible with their values and goals. But it will also take a movement of parents, educators, public interest groups, and policymakers to force Google and other kids marketers to act responsibly. If we want to see the next generation grow up without being greatly influenced by the most powerful advertising apparatus yet developed, this is a fight we must join. -
News
Child and Consumer Advocates Urge Federal Trade Commission to Investigate and Bring Action Against Google for Excessive and Deceptive Advertising Directed at Children
So-called âFamily-Friendlyâ YouTube Kids App Combines Commercials and Videos, Violating Long-Standing Safeguards for Protecting Children
Washington, DC â Tuesday, April 7 â A coalition of prominent childrenâs and consumer advocacy groups filed a complaint with the Federal Trade Commission (FTC) today requesting an investigation of Google, charging the company with unfair and deceptive practices in connection with its new YouTube Kids app. The complaint (link is external) details a number of the appâs features that take advantage of childrenâs developmental vulnerabilities and violate long-standing media and advertising safeguards that protect children viewing television. Among the specific practices identified in the complaint are:Intermixing advertising and programming in ways that deceive young children, who, unlike adults, lack the cognitive ability to distinguish between the two;Featuring numerous âbranded channelsâ for McDonaldâs, Barbie, Fisher-Price, and other companies, which are little more than program-length commercials;Distributing so-called âuser-generatedâ segments that feature toys, candy, and other products without disclosing the business relationships that many of the producers of these videos have with the manufacturers of the products, a likely violation of the FTCâs Endorsement Guidelines.When it launched the YouTube Kids app in February, Google described it as âthe first Google product built from the ground up with little ones in mind.â As the complaint points out, however, the company appears to have ignored not only the scientific research on childrenâs developmental limitations, but also the well-established system of advertising safeguards that has been in place on both broadcast and cable television for decades. Those important policies include (1) a prohibition against the host of a childrenâs program from delivering commercial messages; (2) strict time limits on the amount of advertising any childrenâs program can include; (3) the prohibition of program-length commercials; and (4) the banning of âproduct placementsâ or âembedded advertisements.â Such âblending of childrenâs programming content with advertising material on television,â the groupâs complaint declares, âhas long been prohibited because it is unfair and deceptive to children. The fact that children are viewing the videos on a tablet or smart phone screen instead of on a television screen does not make it any less unfair and deceptive.â The complaint also charges that Google is violating its own advertising policies for YouTube Kids. For example, while the company promises that food and beverage ads will not appear on the app, advertising and promotions for junk food are prominently featured throughout. âYouTube Kids is the most hyper-commercialized media environment for children I have ever seen,â commented Dale Kunkel, Professor of Communication, University of Arizona. âMany of these advertising tactics are considered illegal on television, and it's sad to see Google trying to get away with using them in digital media.â âThere is nothing 'child friendly' about an app that obliterates long-standing principles designed to protect kids from commercialism,â added Josh Golin, Associate Director of Campaign for a Commercial-Free Childhood. âYouTube Kids exploits childrenâs developmental vulnerabilities by delivering a steady stream of advertising that masquerades as programming. Furthermore, YouTube Kids' advertising policy is incredibly deceptive. To cite just one example, Google claims it doesn't accept food and beverage ads but McDonald's actually has its own channel and the 'content' includes actual Happy Meal commercials.â Angela J. Campbell of the Institute for Public Representation at Georgetown Law, who serves as counsel to the coalition, called on the FTC to "investigate whether Disney and other marketers are providing secret financial incentives for the creation of videos showing off their products. The FTCâs Endorsement Guides require disclosure of any such relationships so that consumers will not be misled." âIn todayâs digital era, children deserve effective safeguards that will protect them regardless of the âscreenâ they use,â explained Jeff Chester, Executive Director of the Center for Digital Democracy. âIn addition to ensuring that Google stops its illegal and irresponsible behavior to children on YouTube Kids, new policies will be required to address the growing arsenal of powerful digital marketing and targeting practices that are shaping contemporary childrenâs media culture â on mobile phones, social media, gaming devices, and online video platforms.â Organizations signing the complaint include: the Center for Digital Democracy, Campaign for a Commercial-Free Childhood, American Academy of Child and Adolescent Psychiatry, Center for Science in the Public Interest, Children Now, Consumer Federation of America, Consumer Watchdog, Consumers Union, Corporate Accountability International, and Public Citizen -
Blog
CDD files Appeal to make public NIST grant to Privo
Disclosure required on kids privacy issue involving Privo's partnership with a toy company and Verizon
The Children's Online Privacy Protection Act (COPPA), a federal law my NGO led the campaign for back in the mid-1990's, was designed to ensure that parents (or the responsible adult) be able to make meaningful decisions about commercial data collected from a child (thru age 12). It's based on a concept requiring serious (read honest) and full disclosure of data collection and use practices, with prior affirmative consent (informed opt-in) before any collection occurs. Given the powerful array (link is external)of digital marketing techniques focused on collecting our information, and the need to ensure that parents have federal safeguards for the children's privacy, COPPA means that online marketing companies and their partners need to act in a highly responsbile, transparent and truly privacy appropriate manner.We are concerned that some in the online marketing industry want to create an easy "one-stop shopping" process that encourages parents to approve data collection for their child. Kids are a very lucrative market, spending (link is external)and influencing many billions a year. Some companies view COPPA as an obstacle to their plans to generate profits by online marketing to kids. Despite claims of respecting privacy (and which can also be viewed by examining the commercial market targeting adolescents), the default most marketers have adopted is full non-stop personalized data collection and real-time targeting. But COPPA makes such practices, commonplace in the digital ad industry, much harder to do. In part, it's because under the law they have to actually explain first what they intend to do and get permission. That approach is anathema to most in the online marketing business.When we learned that the National Institute for Standards and Technology (NIST, a division of the Department of Commerce) gave a federal $1.6 million grant (link is external)to Privo (link is external)designed to create a "parent consent at Internet scale" system for COPPA we were concerned. Privo's partners in its grant include "one of the world's largest toy companies" as well as Verizon (link is external). CDD, through our attorneys at the Institute for Public Representation, Georgetown Law Center, filed a FOIA request. The public needs to know how Privo's (link is external) system will operate; whether it's really designed to help parents make meaningful decisions; what role does the major toy company and Verizon (which has expanded (link is external) its own data targeting apparatus) play.NIST redacted nearly all of the Privo related documents, failing to provide the public the information and accountability necessary (especially when it's about the privacy of children). Today, we filed an Appeal and intend to pursue our legal options. (See attachment below.) More details coming. -
Youth of color are a key focus for digital marketers, especially for fast-foods and beverages linked to the youth obesity epidemic. The digital targeting of African American and Hispanic youth is growing, and uses a full array of sophisticated mobile, geo-location, social media and other cutting-edge marketing strategies. Food and beverage marketers should adopt practices that stop unfair and irresponsible digital marketing practices. The FTC and State AG's should call for safeguards.Here's the latest CDD Infographic that addresses African American youth.
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News
Protecting Children's Online Privacy: A Parent's Guide to the new stronger kids privacy rules for digital media(COPPA)
The new FTC rules designed to better protect children's privacy kick-in on July 1, 2013. CDD and colleagues led a four-year campaign to help create these safeguards. The new rules better protect kids from stealth online tracking, the collection of their geo-location information by apps and mobile devices, data gathered by social media, etc. Here's a guide for parents to help them understand how to make COPPA work for them. Groups interested in learning how they can monitor online sites to ensure they are following the new safeguards, as well as file complaints with the FTC, can email us for a free COPPA compliance guide. -
In a 4-0 decision, the FTC agreed with CDD and a coalition of consumer, public health, and child advocay groups to reject calls from the online marketing lobby to delay the implementation of the new COPPA rules. The decision can be read here. (link is external)Our coalition's oppostion to the industry request played an important role in the commission's decision. It can be reviewed here. (link is external)The commission's action sent an important message that protecting the privacy of children and empowering parents/caregivers is a core value which must be respected.
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Blog
CDD Presentation at World Health Org on Digital Alcohol Marketing
We will present this Wed. at the WHO's Global Alcohol Policy conference. Our presentation is: The Digital Marketing of Alcoholic Beverages to Youth: How Social Media, Mobile Devices, Personalized Data Collection and Neuromarketing have transformed the global advertising landscape.
Here's the abstract.Powerful new digital marketing techniques permit beer and alcohol companies to deeply penetrate into the hearts and minds of consumers, and their social networks of friends. The growing sophistication and capabilities of online marketing, increasingly integrated into the lifestyles of youthful and Internet connected consumers throughout the world, pose potential public health concernsâas well as opportunities. Marketing today has been transformed from the viewing of a single advert on television or in print, into experiencing interactive and highly personalized content that influences what we consume and purchase. Alcoholic beverage companies are winning global awards for their campaigns, including those launched in the Asia Pacific, EU, North and South America markets.Today, a single user can be stealthily tracked and profiled throughout their âonline journeyââincluding their visits to many websites and they actions they take--as their information is collected and analyzed. Then so-called online âbehavioralâ advertising takes this profile data to target an individual user more precisely.. Mobile phone and location marketing permit marketers to âgeo-targetâ users in specific geographic areas and at defined times. Digital advertising can operate across so-called multiple platformsâfollowing a single consumer whether they are in front of the personal computer, using a mobile device, or even soon while watching television. Super-fast computers are able to identify a single individual who might be a suitable target for an online alcohol adâand sell them in real-time to the highest bidder.Facebook and other social media enable marketers to go beyond the targeting of individuals to also influence and âactivateâ ones network of friends. The goal for much of social media marketing is to encourage consumers to do the marketing for the brand, through new forms of viral and other âpeer-to-peerâ endorsements. Millions of Facebook members are now regularly reached by alcoholic beverage companies.Online marketers are increasingly relying on the use of âneuromarketingâ to create ads and other content expressly designed to penetrate the subconscious minds of users. Through the use of âimmersiveâ online content, including entertainment, digital marketers are creating new forms of story-telling designed to increase brand loyalty and sales. -
(Full Report - PDF (link is external) )(Brief Report - PDF (link is external) ) Written by Jeff Chester, Center for Digital Democracy, and Kathryn Montgomery, American University A report from Berkeley Media Studies GroupToday, U.S. children are confronting myriad diseases associated with excessive weight gain and poor nutrition. Type 2 diabetes, a serious medical condition previously found only in adults, has become common in children and adolescents. Government agencies and public health professionals have become increasingly concerned over the role of advertising in promoting "high-calorie, low-nutrient" products to young people. Most of the policy debate has focused on TV commercials targeted at young children. However, marketing now extends far beyond the confines of television and even the Internet, into an expanding and ubiquitous digital media culture. The proliferation of media in children's lives has created a new "marketing ecosystem" that encompasses cell phones, mobile music devices, instant messaging, videogames, and virtual, three-dimensional worlds. These new marketing practices are fundamentally transforming how food and beverage companies do business with young people in the twenty-first century.