Should Advertising Directed at Children Be Restricted?

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The following is adapted from an essay I wrote a few years ago as part of my graduate program at Avila University.

Advertising to children is a bit more complicated than it used to be. It's not all about what's on TV any more, and the ability to track children online can raise concerns about manipulation and data collection. Still, I'm not certain the situation is as dire as some would have us believe.

Confessions of an '80s Cartoon Kid

As a kid growing up in the 1980s without cable television, Saturday morning cartoons were a big deal for me. Every Fall I even made a point of watching the preview shows that aired during prime time on the major networks, introducing the new cartoons coming up for the season. When my family got our first VCR my mother gave me a tape to use, and I carefully programmed it every week to record one of the three networks while I watched one of the other two. Then, during the week, I'd watch an hour or so of cartoons from that tape after school. Obviously, once it got into repeats, I started recording the unwatched network, and rewatched cartoons on Saturday from one of the other two. With all that consumption of cartoons implicitly advertising for products, you'd think I must have been constantly craving those specific toys and other products. It didn't quite work out like that.

One of the cartoons I remember most was Disney's Adventures of the Gummi Bears. I think it was the sanitized medieval aesthetic that appealed to me. I'm not sure it was ever my favorite, but I certainly enjoyed it a great deal. What I didn't like were actual Gummi Bears candies. I still don't like them. They have a texture I don't like, and honestly they always seemed too bland to me. I like sugar. It's possible I ate some cereal branded with the Gummi Bears, though I don't remember it. I never owned a Gummi Bears toy. What I did have, though, were a lot of He-Man toys. Wow I loved those action figures. I ended up spending almost all the Christmas and birthday money I'd saved for a few years on them. It was sort of a problem. And yet, I never saw a single episode of He-Man until I was a teenager. You see, that series aired on cable, which we didn't have.

Imagine my shock when I heard Skeletor's obnoxiously whiny voice for the first time!

A significant factor controlling the influence of advertising on children is access — or lack thereof — to money and a means to use it. While I spent nearly every dime I had on He-Man, I couldn't spend any more than that. My parents didn't have money growing on trees, and they weren't overindulgent. I got new toys on my birthday and at Christmas, and rarely at any other time. Other parents weren't like that, I know. One friend of mine had limited floor space in her bedroom because of all the toys. They tumbled out of her closet, filled one section of the basement, and a playhouse out back was converted to additional storage for the overflow. It was a bit much.

In any event, the buying power of children is limited naturally by what their parents are willing to do, and in our times by those same parents having the foresight to block their children from having Alexa order them new toys.

A Different Kind of Ad, A Different Kind of Risk

When it comes to advertising to children on the internet, we're in new territory with certain risks that don't come with TV and magazine ads. Online advertising depends on data collection. If I shop around online for a new mattress I can be pretty certain that I'll mostly see ads for mattresses, beds, and bedding for a while. Facebook even has "shadow profiles" of people who aren't Facebook users, based on their online activity involving sites where Facebook ad partner code can be found. Bring this to bear on children under 13, and we have a formula for potential manipulation and the additional risk of gathering personal information about children that could put them at risk. Location, for example, is not something about a child that you want falling into the hands of hackers, or site owners with evil intent.

Learning COPPA the Scholastic Way

The first time I heard about COPPA, The Children's Online Privacy Protection Act, was during my first week at Scholastic in New York. I'd been hired as a product manager, and while my prior experience had been in magazine publishing (Wired.com in particular), it hadn't been directed at children. Every discussion about creating or updating a website, launching an app, or developing a new online game began and ended at Scholastic with a discussion of the COPPA implications. To make the explanation a little simpler, here are the steps the FTC sets for companies to evaluate their online offerings:

Step 1: Determine if Your Company is a Website or Online Service that Collects Personal Information from Kids Under 13.

Step 2: Post a Privacy Policy that Complies with COPPA.

Step 3: Notify Parents Directly Before Collecting Personal Information from Their Kids.

Step 4: Get Parents' Verifiable Consent Before Collecting Personal Information from Their Kids.

Step 5: Honor Parents' Ongoing Rights with Respect to Personal Information Collected from Their Kids.

Step 6: Implement Reasonable Procedures to Protect the Security of Kids' Personal Information. (FTC)

Additionally, here's how the FTC evaluates sites and services potentially directed at children:

"The FTC looks at a variety of factors to see if a site or service is directed to children under 13, including the subject matter of the site or service, visual and audio content, the use of animated characters or other child-oriented activities and incentives, the age of models, the presence of child celebrities or celebrities who appeal to kids, ads on the site or service that are directed to children, and other reliable evidence about the age of the actual or intended audience. If your website doesn't target children as its primary audience, but is 'directed to children under 13' based on those factors, you may choose to apply COPPA protections only to users under age 13. If that's what you decide to do, you must not collect personal information from any users without first collecting age information. For users who say they are under age 13, don't collect any personal information until you have obtained verifiable parental consent." (FTC)

Scholastic has a clever way of avoiding even inadvertent collection of data regarding children. When a child registers on their site for access to games and so forth, they are guided through steps that generate a truly randomized user name. By letting them choose something that is their favorite and that they consider the coolest, Scholastic gives children the sense that this user name is personalized, when in fact it's really pretty vague. Further, Scholastic places no tracking at all on portions of the site that involve children, and severely restricts it even where the intended users are parents and teachers.

Nickelodeon, a brand where I currently work (Viacom), takes similar precautions, and also includes a "bumper" page between the site itself and any destination away from a kids-oriented page, alerting the user of the change and that the privacy policy beyond that point will be different. I'm sure this never stopped a kid from clicking through, but it gives Viacom a little legal protection.

Then There's Social Media, and the Unboxing Video

If that were all there were to dealing with children online, matters would still be quite simple. Of course, it isn't all summed up so nicely. Consider the influence of social media, wherein children encounter their peers, or people behaving as though they were their peers, promoting products and mocking others. A phenomenon I find somewhat baffling is the unboxing video. In these productions, people buy and then carefully open and discuss the purchase, including comments on the packaging and slow, deliberate looks at each element of the product as it is brought forth. While these are made for adults as well, children eat them up. Check YouTube and you might be amazed at how many hundreds of thousands of these videos exist.

Last month, a global survey asked 3,000 children ages 8-12 to share their career goals. The number one aspiration for kids in China? Becoming an astronaut. The number one answer for kids in the U.S.: Becoming a YouTuber/vlogger. (Zfat, 2019)

Why YouTube Is In Trouble When Scholastic Isn't

The secret to why Scholastic is so good about managing advertising around children, and Nickelodeon is working hard to catch up in that regard, is no secret at all. The FTC took legal action against both in the past for violating COPPA. Now, it's YouTube's turn in the regulatory spotlight. A settlement was recently announced concerning YouTube's highly questionable practices.

For videos targeted to kids, YouTube will be halting all personalized ads and removing features like comments and notifications in the coming months, YouTube CEO Susan Wojcicki wrote in a blog post addressing the settlement.

Without comments and notifications, the likelihood of a video getting maximum engagement (and subsequently, advertising dollars) could plummet — and a decrease in video engagement could mean a decrease in YouTube endorsing a creator's videos.

It also begs the question: If creators stop making videos targeted to children, what will the 81% of children watching YouTube watch instead? (Zfat, 2019)

Several prominent full-time personalities are already making changes to avoid the potential fallout. Toya from MyFroggyStuff (2.1 million subscribers), Kelli Maple (1.2 million subscribers), and Rob of Art for Kids (1.9 million subscribers), among others, have all published announcement videos updating their fans about changes they should expect to see, including adjustments to both titles and content. Their goal is to avoid losing revenue by being swept up in YouTube's broad new category of kids content, which will go into effect on January 1st, 2020, while still keeping their fans happy. (Alexander, 2019)

The commonality between Nickelodeon and Scholastic is that both are promoting themselves even without targeted advertising. The children play games and watch videos on these sites that are 100% advertising, even though there's no "hey kids, ask your parents to buy" statements. With YouTube this simply isn't the case. Its business model is built around attaching advertising to videos that users upload, monetizing the content and giving a little back to the content creators. YouTube is the service, but the viewers are the product that is being offered up to advertisers, just as is the case on Facebook, Twitter, or any other social media website. Allowing users to upload virtually anything directed at children (or anyone else) has regularly put YouTube and its parent, Google, in hot water.

Where This Leaves Us

Now, without some means of making revenue from them, no one would make toys, games, children's books, or programming for children. There's a definite need to balance the interest in having such things available with the safety and well-being of children. Again, the purchasing is ultimately up to the parents, but gathering personal data and directing advertising in ways that can manipulate undeveloped minds is a matter requiring regulation.

Sources

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