At its most recent meeting, the CARU Advisory Board approved some minor revisions to the Self-Regulatory Guidelines for Children's Advertising, which can be found at http://www.caru.org/guidelines/index.asp. Guideline 5 under "Sweepstakes and Contests" deals with information collection for online sweepstakes and contests and, as previously written, seemed to encourage the collection of more personally identifiable information than was reasonable necessary, in contravention of both the Data Collection section of the Guidelines and COPPA.
Rather than try to prescribe all acceptable methods of information collection for this purpose, the guideline now simply requires that any information collection in conjunction with contest or sweepstakes entry " … must meet the requirements of the Data Collection section of the Guidelines and … COPPA." Below are some suggested methods that comply with the requirements of the Guidelines when the operator knows that the entrant is a child, but the list is by no means exhaustive. We encourage others to identify additional compliant scenarios, for both child-directed and general audience Websites, and to share them with us at elascoutx@caru.bbb.org . We will add them to this Website to provide further guidance for the industry.
- collect only the child's first name or screen name and parent's email address, and notify the parent that that the child has entered the contest and that if the child is a winner the parent will be notified and asked to provide fulfillment information; or
- collect only the child's first name or screen name and email address and, if the child is a winner, notify the child and provide an appropriate method of obtaining the fulfillment information from the parent; or
- collect only the child's first name or screen name and e-mail address, and, if the contest or sweepstakes involves multiple online contacts with the child, the e-mail address of a parent, and notify the parent about (i) the right to opt the child out of further contacts and (ii) fulfillment requirements if the child is a winner; or
- collect only the child's first name or screen name and parent's email address, and obtain consent from the parent before obtaining any additional personal information from the child.
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