Guidelines for Interactive Electronic Media

The Children's Advertising Review Unit Guidelines for Children's Advertising: Guidelines for Interactive Electronic Media

In the United States, the Children's Advertising Review Unit (CARU) has created a series of voluntary guidelines for marketing to children on the Internet. These guidelines apply to online activities which are intentionally targeted to children under 13, or where the Web site knows the visitor is a child. They outline the terms for selling to children online and the rules to protect the personal privacy of young visitors.

Making a Sale

Ideally, advertisers must do their best to prevent children from buying goods online without the permission of a parent or guardian. Advertisers selling to children on the Internet must clearly state the costs of online transactions and provide ways for parents to cancel any orders that kids make without permission.

The CARU guidelines state that:

Children should always be told when they are being targeted for a sale.

Any online ordering instructions must clearly state that a child must have a parent's permission before ordering.

When kids order goods or services online, Web sites must provide parents with ways to cancel any orders made by their children.

Data Collection

Marketers love the Internet because its interactive nature allows them to collect information on potential customers (i.e., through online registration forms, surveys, games and contests). But young children might not understand that any information they give to a site could be used by marketers. When marketers ask for personally identifiable information from children (i.e., full names, addresses, e-mail addresses, phone numbers) this creates special privacy and security concerns.

Because of this, advertisers have to follow specific guidelines when collecting information from children under 13 years of age:

Web sites must include a privacy policy or letter to parents that clearly states:

What information is collected from kids.

What methods are used to track visitors while they are on the site (for example, some sites use 'cookie' software to track which areas kids visit).

How any information collected from kids will be used.

How any information that has been collected from kids can be removed or corrected.

Making sure that parents are aware what information is being collected from their children is an important step in protecting the online privacy of young people. CARU states that verifiable parental consent must be obtained in the following situations:

When kids are asked to submit "real world", personally identifiable information -- like a street address or phone number -- which would permit a company to contact them off-line.

When personally identifiable information about kids will be shared or distributed to third parties that are not connected to the company or Web site.

When personally identifiable information -- such as e-mail addresses and screen names -- will be publicly posted to enable other people to communicate with the child, or the child to communicate with others.

Parents must also be informed if a child contacts a site with a question or request, and in doing so, discloses personal information like a name or return e-mail address. The company must tell parents what they intend to do with this information, and must provide instructions for removing or correcting any information that has been submitted to the site.

Advertisers also have to ensure that kids understand when information is being collected from them. The CARU guidelines state that:

Advertisers must remind children to ask for parental permission before submitting personally identifiable information about themselves or others to a site.

Advertisers have to tell kids, in a language that they can understand, why any information is being requested (i.e., "We'll use your name and e-mail address to enter you in this contest and also add it to our mailing list".)

Advertisers have to tell kids whether the information is intended to be shared, sold or distributed outside of the company that is collecting the information.

If information is collected from children through "passive means" (i.e., navigational tracking tools or browser files) parents and children must be told what information is being tracked, and how it will be used.

Advertisers should encourage kids not to use their real names when they participate in any activities involving public postings where anyone can see the information (like chat rooms or message boards).

If the information requested by a site is optional, and not required to engage in an activity, kids need to be told this in clear, simple language (i.e., "You don't have to answer this question to play the game.") Once again, kids must be told what will be done with any information they submit and advertisers should only ask for reasonable amounts of information.

Part of the Internet's appeal to marketers, is that they can contact kids directly through e-mail. But if an advertiser does this, there should be an opportunity with each mailing for the child or parent to choose to discontinue receiving them.

Source: The Children's Advertising Review Unit Self Regulatory Guidelines for Children's Advertising. The complete CARU Guidelines for Children's Advertising can be viewed on the Better Business BureauWeb site.