Maybe I have a bad attitude…

As I was exploring privacy issues associated with data mining and direct marketing this week, I discovered that the FTC has specific guidelines for online advertisers that require them to provide information about the data they collect and what purpose it’s used for. Now mind you, I assumed there were federal guidelines for online advertising content, but I didn’t realize it had to be that detailed. Probably because it’s buried in  the privacy policy at most Web sites — a link to which is provided in tiny, little letters at the bottom of most Web pages.


In an effort to learn more about the FTC privacy rules, I checked out their Web site and stumbled across the Children’s Online Privacy Protection Act (COPPA), which seemed particularly relevant since this past week’s discussion was about the ethics of marketing to children. According to the policy:

“Before collecting, using or disclosing personal information from a child, an operator must obtain verifiable parental consent from the child’s parent. This means an operator must make reasonable efforts (taking into consideration available technology) to ensure that before personal information is collected from a child, a parent of the child receives notice of the operator’s information practices and consents to those practices.”

After checking out several Web sites for kids this week, I find it hard to believe that most Web sites actually obtain parental consent before collecting personal information from a child. Granted, there were plenty of disclaimers and whatnot for parents on the various sites, but the idea that 1) a marketer would actually ask for the information necessary to contact a child’s parents,  2) a child would actually provide that information, and 3) a parent would actually respond just seems too far-fetched for me.

Just to see, I picked out a random site — Discovery Kids — to find out how they obtain parental consent. The rules are there, but buried in the privacy policy, as expected. They say:

“From time to time, we may request limited personally identifiable information from kids in order to offer a service, a promotion or other activity to the kids. In such an instance, we will request that the child provide his or her email address, as well as the email address of his or her parent or legal guardian (“parent”). Discovery will use that email address to send the parent an email letting him or her know about the child’s contact. The email will include details on how the parent may (i) provide Discovery with consent; (ii) prohibit Discovery from any further contact with the child; or (iii) delete the child’s personally identifiable information. Discovery will not collect more information than is reasonably necessary for the child to participate in the activity at issue.”

The policy went on to indicate that Discovery would seek parental permission if a child wanted to enter a sweepstakes or other promotional contest, or if they wanted to sign up for a newsletter. I tried to find a way to sign up for either one of those, but I had no luck. Perhaps that’s how Discovery avoids seeking parental permission. I don’t know. I’m still skeptical that this actually works, but I do give Discovery credit for notifying kids they are about to enter a section of the Web site that includes messages from advertisers when they click on the “Fun & Games” tab, though I doubt most kids care.

And the FTC does apparently enforce the COPPA rules. I found a civil complaint at the FTC Web site filed against The Ohio Art Company — which operates — for failure to publish its data collection policy or seek parental consent to collect information from kids. So maybe I’m too cynical.



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