CARU Works With Smartees' Dolls Site To Address Children's Privacy
New York, NY August 6, 2001 The Children's Advertising Review Unit (CARU) of the Council of Better Business Bureaus, Inc. is pleased to announce that Smartees Inc. has made modifications to its Website, www.smarteesdolls.com, in order to bring the Website into compliance with CARU's Self-Regulatory Guidelines for Children's Advertising (the Guidelines), as well as the federally mandated Children's Online Privacy Protection Act (COPPA).
CARU discovered the Smartees Website through its routine patrolling of the Internet. Smartees Inc. offers the Smartees doll line, which has been described as "Smart friends for smart girls." The Smartees Website offers contests, a Smartees Club, survey and a Smartees scholarship. CARU found this Website after conducting a search for Websites that referenced CARU's Self-Regulatory Guidelines for Children's Advertising. While Smartees' a statement called "Legal Issues for Grown-ups" claimed that Smartees followed "all of The Children's Advertising Review Unit (CARU) including its guidelines on Internet advertising" the Smartee Dolls' Website featured several infractions of CARU's Guidelines as well as the the federal Children's Online Privacy Protection Act (COPPA). Specifically, the Smartee's Website did not post a privacy policy, in addition Smartees collected extensive personal information from children and failed to obtaining the requisite parental consent for its Smartees Club.
In response to CARU's concerns Smartees drafted a comprehensive privacy policy. In addition, Smartees limited information collection on the Website and implemented a parental consent mechanism for its Club.
Smartees demonstrated a cooperative attitude throughout CARU's inquiry as it worked to redesign its Website to address issues raised under the Children's Online Privacy Protection Act and the CARU Guidelines. CARU is pleased that Smartees, Inc. was willing to take steps toward insuring the safety and privacy of the under 13 audience.
CARU's inquiry was conducted under NAD/NARB/CARU Procedures for Voluntary Self-Regulation of National Advertising. Details of the inquiry, CARU's decision and the advertiser's response will be included in the next NAD/CARU Case Report. Members of the press who wish to see a copy of the decision now should email CARU.
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The National Advertising Review Council (NARC) was formed in 1971 by the Association of National Advertisers, Inc. (ANA), the American Association of Advertising Agencies, Inc. (AAAA), the American Advertising Federation, Inc. (AAF), and the Council of Better Business Bureaus, Inc. (CBBB). Its purpose is to foster truth and accuracy in national advertising through voluntary self-regulation. NARC is the body that establishes the policies and procedures for the CBBB's National Advertising Division (NAD), The Children's Advertising Review Unit (CARU), and the National Advertising Review Board (NARB).
NAD and CARU are the investigative arms of the advertising industry's voluntary self-regulation program. Their casework results from competitive challenges from other advertisers, and also from self-monitoring traditional and new media, including the Internet. The National Advertising Review Board (NARB), the appeals body, is a peer group from which ad-hoc panels are selected to adjudicate those cases that are not resolved at the NAD/CARU level. This unique, self-regulatory system is funded entirely by the business community; CARU is financed by the children's advertising industry, while NAD/NARB's sole source of funding is derived from membership fees paid to the Council of Better Business Bureaus.
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