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Children and the internet - plus ça change,...
by Elizabeth Leonard Lascoutx, Children's Advertising Review Unit

A New ConnectivityThere's been a lot of debate over the last several years about the pros and cons, the enormous benefits and dire risks, presented to children by the internet. Although some of the dialogue has been highly exaggerated-either predicting Armageddon or heralding a Golden Age of information-much of it has been balanced and reasoned, with the great consensus being that with thoughtful piloting, the internet has the potential to be a hitherto unimaginable resource for information, entertainment and community. But before even trying to assess the challenges and opportunities the internet offers to youngsters, it's important to understand the single greatest impediment-the threat to children's privacy-to the flourishing of this still new medium. To do so it's helpful to try to put the discussion in historical context.

With each communication breakthrough of the 20th century the discussion has been much the same. The advent of the "new media," of motion pictures in the early 1900s, radio in the 1920s and television at mid-century all held the promise of wider dissemination of, and more universal access to information theretofore unavailable to most of society. Hand in hand with this cornucopia of knowledge went the "dark side," the effects of exposure to new ideas, unfamiliar cultures and exotic behaviors on the morals of our society. The obvious flashpoint for these fears was the potential harm to our nation's youth. The spectre of young people lured into crime by the glamour of gangster films, frightened by unfamiliar tribal customs, corrupted by sex and drug use depicted in the media, manipulated by corporate sponsors, isolated from friends and social and physical activities by the mesmeric effect of the medium and of the dilution of the influence of family and community all tempered the euphoria over each new medium.

All of this should sound familiar to anyone paying even the slightest attention to the current debate. With varying degrees of legitimacy, alarms have been raised over violent, adult and sexual content available to children, branding and over-commercialization of websites for kids, the increased alienation of children consumed by surfing and interacting online, the highjacking of personal information from unsuspecting youngsters and the dangers of predators lurking in chatrooms.

A cursory glance at this far from exhaustive list reveals that only two of these concerns-extracting personal information from young children and the hazards of unchaperoned children in chatrooms-are unique to the new interactive media, and both stem directly from that very interactivity. Without delving into the relative merits of the other concerns, it seems reasonable to suggest that as a society we have both the means and the responsibility to address them. Parents have always had the primary responsibility in deciding what their children should view or listen to-the right and obligation to "just say no." In the traditional media that's meant supervising their kids' consumption, in some instances with the assistance of industry rating systems, and setting time limits. This is made more difficult when kids are so much more computer savvy than their parents, but there are tools to help parents filter and limit their children's travels on the internet. Parents, teachers, coaches, clergy and others each have an important role to play in encouraging children to participate in group activities and sports. Media literacy education and a robust advertising self-regulation program do a far better job of preparing youngsters to live in the real world and make intelligent choices about products than does shielding kids from marketing messages until they're deemed old enough to process them. Finally, the argument that media are the cause of the diminution of the influence of families in our society is a specious one; most serious students of this phenomenon agree that the increase in single-parent households and in families with two working parents have a much greater effect on the changing face of the family constellation.

So what is it that distinguishes data collection and chatrooms from our children's past experiences with media? The same thing that makes all of the internet so exciting, so vibrant and seductive: interactivity. Suddenly kids aren't just being talked at; they can talk back, participate, vent and even affect the complexion of the message they and others are receiving. In chat rooms and on message boards they can even initiate "content." In a culture enamored of role-playing games like Dungeons and Dragons, they can assume different cyber-identities and even the shyest "geek" can become the smart, successful, self-assured, sexy captain of the team he yearns to be. Children in sparsely populated outbacks, or in urban areas where they're not allowed to travel alone, can find a community to share their passions, fears and problems right on their desktops.

Kids, of course, weren't the only ones who quickly embraced the interactivity of the medium. Early on, marketers recognized the unprecedented opportunity to gather information effortlessly and seamlessly. Website registrations, polls, contest entries, and online questionnaires could now take the place of costly focus groups and other research, affording almost limitless access to information ranging from names and addresses, family incomes, favorite colors, sports figures, hobbies, etc. Marketers jumped at the chance and soon children's websites were filled with games eliciting information, offering incentives and prizes in return for filling in fields asking the make of the family car, parents' occupations, favorite family vacation spots in addition to personal information about the children themselves.

This is indeed revolutionary as far as media experience goes, but the only real difference from the past is that unlike in the physical world, parents aren't involved in the decision to allow their young children to participate. Any ad agency that wants to run a focus group of children knows it first has to approach a parent. In the offline world, if a child wants to send for a special free offer from a cereal box, or join a kids' club, chances are that she will ask Mom for a stamp, or to mail it for her. And when the premium or club newsletter arrives in the mail, Mom or Dad will probably be the one to see it first. In all these instances, the parent will at least have the opportunity to mediate-to say "I don't want you to ask my kid questions" or "No honey, I don't think you should send for/join that." Few parents would allow their young children to visit with friends without an adult on call, no less hang out with groups of masked strangers. But when the interaction takes place with the click of a mouse, when the virtual prizes or newsletters arrive by e-mail, and when children masquerading as teenagers can fraternize with others wearing their own disguises, for the first time young children are able to engage with the world at large without their parent's knowledge or consent.

The issue of children's privacy first grabbed the spotlight in the US in the mid-1990s when the independent concurrent efforts of the government, industry, and advocacy communities converged in a series of remarkably positive, thoughtful, and productive workshops. Although the proposed solutions ranged from strong central regulation through industry self-regulation to a market-driven approach, all sectors agreed that the goal must be to make this aspect of the online environment for kids and parents as similar as possible to past real-world realities by putting the parents in charge again.

The concept is a pretty simple, common sense one. Make sure parents have notice of what information is being asked of their children, and the right (and the means) to grant or withhold consent. The first guidelines setting forth just how to go about providing notice and obtaining consent were published back in 1996 by the Children's Advertising Review Unit, the national voluntary advertising self-regulation body for children's advertising, established more than 20 years earlier by the advertising industry. These first guidelines called for website operators collecting personal information from children under 13, or allowing such children to interact online, to make "reasonable efforts ... to establish that notice is offered to, and choice exercised by a parent or guardian." Since then the guidelines have evolved based on further learning about what's effective, what's feasible, and what it is that kids really are doing on the web, and industry's response has been impressive. As required by CARU's guidelines, marketers have scaled back on the amount of information solicited from kids without parental consent, collecting only that which is "reasonably necessary" to participate in an online activity. Website operators are making good faith efforts to identify underage visitors and provide or obtain the requisite notice or consent. And new and emerging technologies such as digital signatures and P3P are providing websites and parents alike with new tools to facilitate consent.

In October 1998, the US Congress passed the Children's Online Privacy Protection Act (COPPA), which essentially codified CARU's self-regulatory guidelines and took effect in April 2000. Even with the legislation in place, the US Federal Trade Commission, the agency charged with enforcing COPPA, has recognized the primary role of self-regulation in this area by creating a "safe harbor" for industry members who participate in and comply with self-regulatory programs. By stepping in early in the debate and proactively embracing a strong and meaningful self-regulatory program, the US industry has been able to de-fang the thorny issue of children's privacy, level the playing field among the old and new media, and create an environment in which we can nurture this medium to its full potential, and see whether it proves to be boon or bane to our children.

Elizabeth LascoutxElizabeth Leonard Lascoutx has been director of the Children's Advertising Review Unit since 1995. She is also a vice president of the Council of Better Business Bureaus. She began her career at CARU as its staff attorney in January 1991. She led CARU's comprehensive revisiting of its Self-Regulatory Guidelines for Children's Advertising in 1996 to include the new online media and children's privacy. These new "Guidelines for Interactive Electronic Media" ultimately formed the basis for the Children's Online Privacy Protection Act of 1998 (COPPA). In 1999, Ms Lascoutx was honored with the first annual "Cyberangel of the Year" award by Cyberangels, the largest online education and safety organization. That same year, she was named to the US National Action Committee of UNESCO's worldwide internet safety project, Innocence in Danger.



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