Nearly 20% of kids aged 2 to 5 can play with a smartphone app; only half that many can tie their shoelaces.
This tidbit, courtesy of an international “Digital Diaries” study released earlier this year by security software maker AVG , is but one more affirmation of what marketers already know: children are using digital media at ever younger ages and in ever larger numbers. The access to young minds is easier than ever and a dearth of regulation with any sort of teeth is fuelling online campaigns that deliver tantalizing, trackable brand presence that would never be allowed on TV or in print.
It’s no surprise, then, that 90% of Canada’s 50 most popular kids websites contain advertising, and many are advertainment—games and activities centred around toys, TV characters and other branded content . The audience is there for the taking—unregulated and engaged—and so are the ads. But don’t expect the free ride to last because outrage at the Wild West approach is rising, echoing the man who perhaps did more than anyone to sound the alarm on advertising to children, online or off: “Children should not be subjected to one-sided conversations with college-educated adults armed with state-of-the-art psychological tools and processes all aimed at selling them something,” says Alex Bogusky. “It’s a moral issue.” Although you’d be hard-pressed to fi nd marketers or agencies willing to trumpet their lead-gen numbers for 6-year-olds, the fragmented watchdogs are poised to put some bite behind their bark. Interactive advertising to kids today is framed almost entirely by self-regulatory measures that form an Alphagetti bowl’s worth of acronyms. The CRTC has taken a hands-off approach to the internet, and the Personal Information Protection and Electronic Documents Act (PIPEDA), Canada’s private sector privacy law , provides only vague privacy protection for kids.
(The exception is Quebec, where all advertising to kids under 12 is banned, although, like everywhere, online advertising is rife and not enforced). In 2004, Advertising Standards Canada (ASC) introduced an Interpretation Guideline to the Canadian Code of Advertising Standards that covers advertising to children in non-broadcast media, which covers new media. Unlike commercials aimed at children, however, there is no up-front clearance process for digital campaigns .
The Canadian Marketing Association has separate guidelines for its members covering marketing to kids and internet marketing. The Canadian Children’s Food & Beverage Advertising Initiative (CAI), another voluntary measure led by 19 marketers, last year expanded its commitment to limit promotion of unhealthy products to young kids to include interactive games, mobile phones and other digital channels. As for enforceable regulations, however, “they really don’t exist,” says Linda Millar, education specialist with Concerned Children’s Advertisers (CCA), a group that promot es ethics and responsibility in advertising to kids and whose members range from food manufacturers to broadcasters.
Last year, the Offi ce of the Privacy Commissioner of Canada (OPC) held consultations on issues including online tracking and behavioural advertising to learn more about industry practices and explore their privacy implications, including those surrounding information collected from children. “We want to better understand the privacy implications,” says Anne-Marie Hayden, communications director at OPC, which protects and promotes individuals’ privacy rights. “What we learn may infl uence how we approach the next review of the private sector law, which is anticipated for [this year].” The upshot, says Mike Farrell, head of research at Toronto’s Conversion Marketing-Communication, which advises brands on new-media strategy, is that federal regulations are coming “for sure” within the next year or two.
Here’s how to prepare for that inevitability, while preemptively keeping parents from Tweeting in rage at your campaign liberties.
1. Use What You’ve Got
With so few regulations, kids-focused online campaigns are PR minefi elds. But there is a map which can show you where to tread. Janet Feasby, vicepresident, standards at ASC, points to the Canadian Code of Advertising Standards and its Interpretation Guidelines, and especially the one titled “Advertising to Children,” which covers non-broadcast advertising. “My advice is when advertisers in online media—or print or anything—are advertising to children, follow the Interpretation Guidelines, which are essentially the same as the broadcast code,” she says. Guidelines include “Children must not be directly urged to purchase or to ask their parents to make inquiries or purchases,” and advertising to children must “not attempt to collect from children data related to the fi nancial situation or to the privacy of any member of the family.” Feasby adds that Canadian advertisers have adhered to those different sets of codes now in place. CCA’s Millar also says advertisers are being cautious in advertising to kids under 12, and fi nds most marketers are applying the Broadcast Code for Advertising to Children to online, which the CCA advocates.
2. Involve the Parents
The industry should set the agenda and work with the government and, more importantly, with parents to establish mutually agreeable standards. “The same rules need to apply [online]: be transparent, work together with parents and kids to come up with strategies, always involve consumers,” says Farrell, who used to head up research at now-defunct fi rm Youthography. “With young kids, you need to get permission.” Farrell nevertheless argues that the marketing community needs to become much more proactive on this issue. “We need to play an advocacy role right now and work with government and parents to form the ground rules,” he says. Anything that feels “subversive” should be avoided, including in-game ads and intense branding aimed at primary-school kids. “There’s an optics piece that’s incredibly important,” he says. “Everyone I talk to about this has a sense of where the cut-off is… We’re all protective of our children, and there’s the sense of lack of permission being granted by these kids.”
3. Know Where to Draw the Line
Matthew Johnson, director of education at the Media Awareness Network (MAN), an Ottawa-based educational non-profit, says marketers should avoid linking through to advertising from content with “click here” or “play now.” These calls to action are increasingly prevalent, and Johnson says it blurs the lines between branding and content. And when it comes to using branded characters in narratives or games, Johnson recommends avoiding it completely. “It confuses content and advertising on a fundamental level and makes it very hard for youth to tell the difference,” he says. He also suggests that marketers stay away from advertising to kids through social media. He’s especially wary of techniques like “friendvertising,” which solicits recommendations of a product or service. “Youth rely heavily on their friends’ and peers’ opinions in making decisions, and using these networks to try to reach them effectively short-circuits their critical faculties,” says Johnson. This is risky since lots of kids sign up to social networks before they’re technically allowed to, and are then exposed to more mature advertising content.
He also advises against the “instant buy” options that let children pay for in-game goods and services without permission from mom and dad each time. Earlier this year, an 8-year-old girl spent $1,400 at the App Store on a Smurfs’ Village app and a PR black eye for Apple resulted.
4. Respect Privacy
“It’s amazing how commercialized kids’ online experience is,” says Johnson. He suggests marketers provide a clear, consistent demarcation between online content and advertising. Keeping content on the left two-thirds of the page and always placing ads on the right third, for example, could work to give kids reliable cues to distinguish between the two. Johnson thinks the industry needs clear industry guidelines for things like data collection. “Children’s demographic info is a valuable commodity,” he says. “Both commercial and less commercial sites will buy and sell demographic information they get through surveys and even registration forms.” He’s worried about young kids being manipulated into divulging information on how old they are and where they live.
In the U.S., where the Children’s Online Privacy Protection Act (COPPA) has been used for more than a decade, advertising industry groups are moving to beef up self-regulatory measures surrounding privacy. Of particular concern is “behavioural targeting,” wherein websites track and build profiles of user activities online to customize which ads to show them and when. There have been calls for do-not-track lists that make the practice opt-in. Up here, the Interactive Advertising Bureau of Canada developed a fourpoint self-regulatory plan for behavioural targeting in 2009 and has since presented it to the OPC. Paula Gignac, president of IAB Canada, says the first stages of the self-regulatory initiative are slated to roll out this year. So far, seven industry associations, including ASC and the Canadian Marketing Association, are also onboard with the plan. While the current industry standard among publishers and ad networks is to avoid behavioural targeted ads for children under 13, it’s not in IAB’s selfregulatory principles yet, says Gignac. “We’ll put that into our principles and that will make it part of the industry self-regulation.” That move would help crystallize what is and isn’t acceptable with behavioural targeting. The credulity that makes children susceptible to brand advertising from an early age also makes them experience the internet differently. “When younger children… are online, they expect ‘the public’ to be composed of other kids,” notes a draft report released by the OPC last fall. “They are not aware of the invisible audience.’”
5. Use the Same Standards Across Different Platforms
The fire being lit under regulatory bodies and marketers is the public perception that advertisers are abusing their online freedom. Despite commitments like CAI (mirrored in other countries), for example, a study published last May in the U.S.-based Journal of Nutrition Education and Behavior called “Characteristics of Food Industry Web Sites and ‘Advergames’ Targeting Children” found that games on kids’ websites in the U.S. contained one “healthful” message for every 45 brand exposures. Plus, the foods promoted were almost exclusively high in sugar and fat. Judy Sheeshka, the author of a recent Dietitians of Canada paper that criticized the food and beverage industry’s ad practices, notes that CAI members can choose which platforms they use.
“They can pledge to market more healthy foods on TV, but we don’t see the same commitment about online gaming because no one is really going after them for that.” Self-regulation is a giant grey zone. Broadcast rules, for example, prohibit companies from using their brand mascots in kids’ shows to avoid blurring the line between ads and programming. Yet such brand characters are staples of online activities. “It’s so much more difficult to distinguish content from advertising online,” says Johnson, whose research has found that three-quarters of kids in Grades 4 to 11 don’t think of online games as advertising. “Young people will spend an afternoon on the internet and all that time they’ll be on a branded-content site.” And while advertisers on children’s TV channels can’t show more than one commercial for the same product within a half-hour period, some branded websites keep children immersed in games and content for 30 minutes or more at a time. Johnson believes marketers and website designers should take the effects of excessive screen time and exposure to advertising on kids into account when deciding whether and how to use techniques to make sites “sticky.”
He’s referring to things like rankings, points, loyalty programs and the option to customize avatars on sites. Kellogg Canada is taking the potential harmful effects seriously. As part of its commitment to CAI, the food company has pledged to include an automatic use break feature that kicks in after 15 minutes of screen time in interactive games. It’s the kind of kidfriendly step Advertising Standards Canada’s Feasby says other advertisers could follow.
6. Is It Even Worth It?
Does targeting 7-year-olds with marketing on digital media pay off the same way it does with tweens? No, says Conversion’s Farrell. It’s not until a youngster hits the tween years that their voice in household purchasing gets louder (and gets parents reaching into their wallets). Ad spending seems to be moving to that pre-pubescent demo– especially as the use of the mobile “third screen” spreads through the tween world. Pre-tween kids should be left alone, he says–for morality and ROI.
