CDD Letter Urges FTC to Protect Children From Online Marketers
- by Ross Fadner , June 8, 2004
The letter, issued Monday from the Center for Digital Democracy's Executive Director Jeffrey Chester to the FTC Chairman Timothy J. Muris and his fellow commissioners, was vague as to what the "nature" of such practices refers to in this context, and claims that the increased integration of advertising and promotions into online content poses a threat to younger generations, who are unable to distinguish between marketing messages and original content.
According to the letter, the "aggressive marketing practices" unleashed by digital technologies far surpass the limits put forth by the Children's Online Privacy Protection Act of 1998 (COPPA). Under the rules of COPPA, marketers are prohibited from engaging in deceptive marketing practices when targeting children.
Chester states: "The ability of a child or teen to comprehend whether and how they are being marketed to, is fundamentally challenged by the very characteristics of the interactive digital environment, in which the 'word from our sponsor'--no longer segregated in discrete 30- and 60-second segments--is woven into the very media fabric."
He later calls the nature of such advertising "immersive, relational, and ubiquitous," and says that it is detrimental to the development of children, tweens, and teens. In particular, Chester cites the impact of digital marketing on food consumption and obesity as areas of concern.
In a separate statement, Chester cites the emergence of tracking technologies--such as behavioral and contextual marketing and paid search--as problem areas in which policy will need to be set to protect younger consumers. "How this marketing affects such critical developmental issues as cognition/brain development identity formation and the emotional system must be well understood prior to its use on the child-to-teen audience," Chester adds.
Michael Wood, vice president of research firm Teenage Research Unlimited (TRU), disagrees with Chester's assessment of online marketing practices. Wood notes that TRU has never received any complaints about the online marketing practices of companies that target teens and children. "No one has ever come to us, even from a parent perspective, with any horror stories," he says, adding, "there haven't been any incidents at all."
Jeff Lanctot, VP media for interactive agency AvenueA, points out that for kids under 13, marketers and agencies must tread very lightly. Data collection, email campaigns, and deceptive marketing practices are effectively off-limits; all advertising initiatives must be "upfront and explicit," as per the COPPA mandate. "We haven't found [COPPA] unmanageable, and we've never had any problem with it," he says.
TRU's Wood says that kids today have grown up with commercial messages in virtually every aspect of their lives, and because of this, they have learned to put commercial messages in their place. Wood says kids "get turned off" by advertising: "They put up barriers to brands that intrude on their online behaviors and activities," he says, which is why interactive initiatives, like Nabisco's Candystand, are so successful.
Wood calls Candystand.com, an online games venue that showcases various Nabisco brands, a "phenomenal" example of a marketer figuring out the boundaries put up by these tough-to-reach consumers. "They don't care [about the advertising element] as long as it provides the content they want."
AvenueA's Lanctot says that he doesn't find that online advertising targets kids any more aggressively than offline. "In some cases it's more obvious," he notes. Like any new advertising medium, "it's natural to get a fairly high level of scrutiny. Once it's said and done, we'll probably find that online is no more aggressive--and probably less aggressive--than other mediums," Lanctot says.
