Kids Online

The advertising world increasingly views children's advertising as a uniquely profitable multi-billion dollar market. In 1995, children under 12 spent $14 billion, teenagers another $67 billion, and together they influenced $160 billion of their parents' annual spending. (Children in the Digital Age). Children thus provide a three-in-one market as buyers themselves, influencers of their parents purchases, and future adult consumers. Children are confronted with program-length commercials on Saturday morning TV, their own TV and radio networks, magazines, clothing lines, direct mail advertising, as well as corporate sponsored school programs. Parents and educators must now confront the new multimedia, interactive digital universe of the internet which has the power to capture children's attention as never before. Still in its formative stages this world has been recognized as an exemplary resource for a diversity of ideas and information but also as a source of many areas of concern. Public interest advocates for children have focused primarily on protecting children from indecent content on the Internet. Little attention has been paid to the issues of access and the powerful commercial forces shaping the patterns of commercialism of youth in schools and specifically on the WWW. New methods of interactive advertising and marketing practices are being developed to specifically target children in this new medium and with the presence of advertising targeting younger and younger children, schools now face additional pressure to serve their students up as captive audiences to a variety of advertising strategies. It is time to consider the appropriateness of the connection between businesses and schools and develop workable policies as needed especially concerning online advertising .

Questions to consider include:

Should standards exist on internet advertising targeting children?

Should children be protected on the Internet or is it legitimate business to target children?

Do advertisements invade privacy?

What tools are available to safeguard children?

Who should set the standards?

Historical Patterns

Many historical patterns concerning commercialism directed towards children and especially children in schools, shape the arguments both for and against the profliferation of online advertising directed toward children. Supporters of advertising in these arenas propose that commercialism provides useful supplements to the school curriculum, provides a way of raising much needed funds, builds bridges to businesses and the community, and is already so prevalent, that more won't hurt. Opponents counter that commercialism replaces democratic values with market values, places undue pressure on teachers and administrators to subscribe, and offers students up as captive audiences.

Amy Aidman summerizes "Selling America's Kids" a report by the Consumers Union Education Services (CUES) which divides the examples of in-school commercialism into four groups:

1) In-School Ads: This category includes advertising on billboards, scoreboards, art works, book covers and product coupons and incentive awards distibuted in the schools.

One of the most successful of these ideas is Cover Concepts Marketing Services in Braintree, Massachusetts who began giving away free textbook covers, with ads from major corporations such as Nike and McDonalds, to schools. One research study found that brand name recall was up to 74% for Cover Concepts advertisers at the end of the school year and that Cover Concepts collects demographic data directly from the schools, a highly coveted database. (Hittin' the Books)

2) Ads in Classroom Materials and Programs: This category includes commercial messages in magazines or video programming in the schools.

The most publicized example of this category is Channel One. This twelve minute daily news show targeted for students in grades 6 through 12 provides for two minutes of "age-appropriate" advertising for products desirable to this age group. Schools who agree to air the program each day receive a satellite dish, cable hookup and television for each classroom.

3) Corporate-Sponsored Educational Materials and Programs: This category includes the more subtle materials supplied by corporations such as posters, activity sheets and multimedia kits.

These programs are directed towards teachers as well as students. An example is Intel's "The Story Inside" multimedia kit with video tapes and sample materials to help teach the complicated story of how computers work. Offered free to teachers, this sophisticated multimedia kit also contains information promoting the company's products. The world of science education is replete with offers to receive needed equipment in exchange for attendance at a corporate training session.

4) Corporate Sponsored Contests and Incentive Programs: Brand names are brought into the school with rewards such as free food, admissions, trips or points toward buying educational supplies and equipment.

Examples of this type of advertising abound. Coupons for free pizza or skating, points for using a phone service to be exchanged for educational materials, the list is endless.

Organizations that support guidelines to address the flow of commercial messages into schools include the Association for Supervision and Curriculum Development, the National Parent Teacher Association, and the National Education Association. Both the Society of Consumer Affairs Professionals in Business (SOCAP) and Consumers International suggest that "education materials should be accurate, objective, clearly written, nondiscriminatory, and noncommercial." The Consumers Union supports the notion of schools as "ad-free zones" and suggests a three-pronged approach that includes:

Holding all sponsored materials and activities to the standards of the SOCAP guidelines
Pursuing noncommercial partnerships with businesses and considering advertising to provide materials and/or funds unethical
Teaching media literacy in schools to enable students to be critical evaluators of advertising and media messages. (Advertising in the Schools)

New Invasion - Online Advertising

Recognizing that children are a large and growing purchasing block and that the estimated one million children using the Web will quadruple by the year 2000, advertisers and marketers have begun to target the number of children using online services for education and recreation purposes. An exhaustive investigation by the Center for Media Educaiton (CME) has uncovered a number of new practices that pose threats for children online. These include:

Invasion of children's privacy through solicitation of personal information and tracking of online computer use:
- eliciting personal information from children through the use of prizes, games, and surveys;
- monitoring children's online activities and compiling detailed personal profiles; and,
- designing personalized advertising aimed at individual children.
Exploitation of vulnerable, young computer users through new unfair and deceptive forms of advertising.
- designing advertising environments to capture children's attention for extended periods of time;
- seamlessly integrating adverrtising and content; and
- creating product "spokescharacters" to develop interactive relationships with children.

(Web of Deception: Threats to Children from Online Marketing)

This invasion is possible because the participatory medium of the Web provides new, powerful tools to capture the attention of children. One third of the estimated 15 million current Web sites are corporate cyber-homes (And Now A Web From Our Sponsor) and those targeting the growing numbers of children online are designed to capture the spending power of children by allowing them to explore, interact, and manipulate information using new, exciting technologies. Real time audio, real time video, Shockwave, Java, VRML--the development of online technological breakthroughs not only enhances the great variety of challenging educational experiences for children online, but opens a whole new set of possibilities to advertisers and marketers to capture the attention of younger and younger consumers. In order to make the best of these new media, as well as avoid the worst, we have a responsibility to develop an understanding of the issues involved and lead in the formation of the policies necessary to protect and best serve our children.

With the FCC's deregulation in the mid-1980's of children's television, toy manufacturers began the wholesale creation of kids programing which served as half-hour commercials for licensed products such as the Care Bears and Power Rangers and these advertisers are moving aggressively into cyberspace. Claiming that "advertising is the only way to make information services affordable to all," groups such as the Coalitiion for Advertising Supported Information and Entertainment (CASIE) are lobbying for advertising as the dominant form of funding online content and working hard to avoid government regulation. (Children in the Digital Age) With no limits on the number and length of ads and no regulation of direct pitches to kids, commercial online services have developed special areas for kids (i.e., America Online "Kids Only") and corporate web sites seamlessly integrate content and advertising, encouraging children to develop ongoing relationships with characters and products as well as divulge personal information in exchange for access to games and contests.
A less than exhaustive list of corporate kids sites includes:

This one-to-one online marketing becomes even more invasive as the technology develops to track user activity online by following their clicks and jumps and then tailoring web sites to match the profile of that particular user. The additional ability to make personal appeals to an individual user will be difficult to resist. Marc Rotenberg, director of the Electronic Privacy Information Center, offers a view of what this may look like:

"Instead of doing a commercial that's roughly targeted to boy's five to seven, which is a lot of the advertising on Saturday morning TV, now you're targeting a particular boy, who has a particular interest in a particular program, who lives in a house, whose parents have a certain income. And at that level of targeting, I think the opportunity for manipulation becomes much greater, really almost overwhelming for parents who are trying to control the upbringing of their kids. Because we've never really existed before in an information environment where the TV could reach out to your child and say, 'Bob, wouldn't you like to have this new action figure, just like in the movie your saw last week?' Little Bob, needless to say, will be flattered and intrigued by this new "TV that talks back" a device that magically remembers his last visit and tailors the next one to correspond to his special interests. It's exciting, this new personalized, interactive media, but it's more than a little unfortunate. Bob and millions of children like him will be transformed. They won't simply be children any more, but something much more valuable to the corporations investing vast sums to develop the World Wide Web: they'll be customers." (And Now a Web from Our Sponsor)

As educators, we must recognize the power of online communications and examine our responsibilities toward developing a vision of the future. We should be leaders in the discussion of the development of carefully considered policies and guidelines that will determine the direction of internet advertising directed towards kids. Unless we involve ourselves in these discussions it is unlikely that safeguards and regulations will be implemented.

Some organizations have already begun to address this critical issue. The Children's Advertising Review Unit of the Council of Better Business Bureau released voluntary guidelines of responsible online marketing to children on April 21, 1997. These guidelines advise that Web sites clearly designate the difference between advertising and editorial content. The guidelines also address issues of privacy and commerce and ask advertisers to make reasonable efforts to persuade chidren to get parental permission before supplying any personal information about themselves or their families. The Children's Online Privacy Protection Act passed by Congress on October 21, 1998 authorizes the Federal Trade Commission to develop rules for regulating data collection on commercial Web sites targeting children 12 and under. It does not, however, regulate the advertising itself or offer any protection for young teenagers.

David V.B. Britt, chief executive of Children's Television Workshop expresses these concerns:
"We have to recognize that children are going to learn from online, whether it's something we think is educational or not. Like television, it's not a question of whether children are going to learn; it's only a question of what they are going to learn. When we do it wrong, with violence or with mayhem or with completely mindless entertainment, they are going to learn from that. And some of them will be harmed. When we do it right, children will learn some things that will help them grow and become better citizens. It's a real and powerful responsibility." (And Now a Web From Our Sponsor)

As adults who regularly guide and supervise children on the WWW we are aware that it is constantly evolving, a work in progress. So how do we "do it right?" The guidelines and regulations that shape this progress have not yet been written, and if nothing else, we should be discussing what direction we want that evolution to take. We cannot afford to take a sit and wait attitude when the potential social, educational, and cultural benefits of the World Wide Web are at stake.

To reiterate the arguments of those who want standards and/or regulation of online advertising targeting children, we must look at practices and techniques that manipulate children and invade their privacy. The Center for Media Education lists three practices that invade privacy:

eliciting personal information from children through the use of prizes, games, and surveys;

monitoring children's online activities and compiling detailed personal profiles; and

designing personalized advertising aimed a individual children.

A second list of practices that exploit young children includes:

designing advertising environments to capture children's attention for extended periods of time;
seamlessly integrating advertising and content;
creating product "spokescharacters" to develop interactive relationships with children; and
micro-targeting children.

(Web of Deception)

Some technology approaches to protect children from commercialism have been developed although all have major limitations. Blocking software can generate lists of visited sites and allow blocking of commercial sites children visit or use key-word blocking. At least one filtering software product prevents children from disclosing addresses or phone numbers while online while one program blocks access to ad banners. The Platform for Internet Content Selection (PICS) is a possible solution only if advocate groups could provide the labor-intensive labeling system.

Without effective technological solutions, some standards seem warrented to "do it right." So, who should set these standards? Who should be in charge? Is government regulation, parent regulation, or self-regulation the answer, or should there be no regulation at all?

All four positions have pros and cons.

Government Regulation

Proponents of government regulation believe that the threats of online commercialism targeting children are just too great not to have the government make the rules. Both the National PTA and the Center for Media Education propose congressional legislation and recommend guidelines including:

personal information shuld not be collected from children or sold to third parties;
advertisments should be clearly labeled and separated from content;
children's areas should not be linked to advertising sites;
no interaction between children and product spokescharacters; and
no online micro-targeting of children.(Center for Media Education Privacy Guidelines)

Opponents of government regulation view such regulation as a form of censorship and cite the Telecommunications Act of 1996 which was declared unconstitutional because it violated free speech, as an example.

Parental Regulation

Proponents of parental regulation feel strongly that it is the prime responsibility of parents to regulate their children's internet use and no outside intervention is necessary. Opponents to parent only regulation believe that too many children use computers alone, that parents lack the time needed to properly guide and supervise children, and that children often have superior computer skills than their parents.

Self-Regulation

Proponents of self-regulation believe that establishing voluntary industry standards such as those proposed by the Children's Advertising Review Unit will give direction to children's advertising practices and by themselves will encourage marketers and advertisers to act responsibly. Opponents observe that voluntary guidelines have not been effective in the past and are likely not to be effective in this new medium.

No Regulation

Proponents of no regulation believe any regulation is a violation of free speech. They also believe that children need to learn about the positive and negative effects of technology and can be protected by learning technology literacy and that advertising ensures that all children will have access to the new technologies. Opponents believe that the dangers of online advertising are too great, that these forms of advertising are new and different, and that children should be protected from possible negative effects.

Kathryn C. Montgomery, in her article Children in the Digital Age outlines three key goals to build public and private efforts for reform:

Ensuring universal access
All children, regardless of economic status, should have access to the technologies for education and full participation in society;
Developing safeguards
International efforts are needed to develop standards for new interactive media since self-regulation is not likely to have an impact unless overseen and enforced by government; and
Creating a noncommercial children's civic sector
Public sectors online should be available to allow children to learn and explore without advertising, manipulation, or exploitation.

This last goal is one that seems most important as the current trend for financing services for children is advertising. However, non-commercial programs and services will require a great deal of money and will require new models of financing to be explored.

Annotated World Wide Web Resources for Kids Online