General Mills Cooperates With CARU
New York, July 2, 2002—The Children's Advertising Review Unit (CARU) of the Council of Better Bureaus Inc. is pleased to announce that General Mills Inc. has agreed to modify both advertising and Website information collection practices in connection with the Hot Breakfast, Cool Room! Sweepstakes.
The sweepstakes, which has been promoted on the Pillsbury.com Website, was collecting personally identifiable information from children under 13. The registration process allowed children to provide parental offline contact information, which is not permissible under either the federal Children's Online Privacy Protection Act (COPPA) or CARU's Self-Regulatory Guidelines for Children's Advertising (the Guidelines). The process also did not have a tracking mechanism which would preclude a child from changing his birth date to avoid parental notification; the privacy policy also did not contain all of the information mandated under COPPA. General Mills made changes to the site to address all of these concerns.
The advertising of the sweepstakes also raised concerns for CARU as to whether sufficient disclosure existed to inform children that there was only one $10,000 grand prize or that the first 300,000 entrants would receive a free premium. In response to CARU, General Mills added conspicuous advertising copy to the Website stating: "Many will enter, but only one will win the $10,000 prize and if you 're one of the first 300,000 entries, you can get free glow-in-the-dark stars."
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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