Deceptive On-line Advertising to Children.


Advertisers have always had provisions and regulations placed on them limiting what they can and cannot do. From broadcast to print advertising, the FTC and other regulatory agencies have tried to insure that children are safe from the influencial messages that advertisers send out. Tobacco companies and alcohol companies have recently drawn the most fire from these agencies, for being accused of targeting children and teenagers in thier advertisements. These companies and others have found new ways to to target kids. They are using the next great advertising medium, the information superhighway, the internet. Companies such as Kellog's cereal company and Hasbro try to get kids to become brand loyal by offering children games to play and contests that they can enter by creating an exciting interactive world where their product logos and trademark characters run the show. Regulatory companies such as the Federal Trade Commision (FTC), the Center for Media Education (CME), and the Children's Advertising Review Unit (CARU) have conducted studies on these practices to see if they violate the FTC's rules on deceptive advertising. So far the FTC has not taken action, but has a lassiez-faire attitude about these sites, possibly for fear of killing the internet with regulations while it is still in it's infancy.






The Ad Monster is reaping the profits by targeting kids

The Issues of On-line Advertising to Kids










Kids and Advertising: Big Business


Advertising to children has become a big business in the past 10 years. It used to be that kids were only marketed to buy cereal, candy, and toys. Now kids are being marketed to for much higher priced items such as computers, airlines, and cars (Kerwin and Leonhardt,1997,63). The reason for this is because it has been estimated that kids 14 and under will spend a total of $20 billion dollars this year and will influence their parents purchases totaling about $200 billion (Kerwin and Leonhardt,1997,63). This means big business for advertisers. It used to be that kids products would be pitched mainly to their parents, opting not to prey on the immature judgment and impressionable minds of children. This allowed parents control over what thier kids, played with, wore, or ate. Today, advertisers have opted to directly target children with all sorts of products, raising the moral issue of fairness. Today, thier are mini-van ads are in kid's magazines and Airlines serve McDonald's Happy Meals to kids (Kerwin and Leonhardt,1997.65).


So? Why can't parent's control what kids watch on TV or what they read? Well, they can. To a certain extent, that is. Parents are busier these days and a lot of times when kids are at home after school, they are the only ones home. And now that kids have discovered the interactive world of the internet, so have the advertisers. The internet, as we all know, is primarily a solitary activity. Sure, parents can watch as thier kids surf the net, but it is nearly impossible to control all of thier on-line actions. Kids also seem to be more at home on the internet than thier parents are these days. According to estimates by Jupiter Communications, nearly 3.7 million children under the age of 18 have Web access, and that figure is expected to quadruple by the year 2000 (CME-Sponsor,3).

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Slick Advertising: How Advertisers Target Children On-line


On-line advertisers try to create web sites that are virtual playgrounds for kids. They use games, contests, and pen-pal programs hoping to get kids to visit thier web sites over and over again. Sometimes these games and contests are free, other times, they come at a price.

This price is usually one which kids inadvertently do not recognize. Disguised as an eloborate advertising scheme, these sites sometimes ask for personal information from kids. This information can then be tracked, analyzed, or audited. With this information on file, companies can sell this information to other companies to specifically target a child. An example of this practice of getting personal information from a child can be found on the Batman Forever site, where children are urged to "Help Commisioner Gordon with the Gotham Census (CME-Sponsor,9)." The way children "help Commisioner Gordon", is to fill out on-line forms that let advertisers know who their audience is. Web sites also get personal information from kids by letting them send e-mail to thier favorite cartoon character. This is what happens on the McDonald's Web site. In order to send a letter to Ronald McDonald, kids must answer a few questions, such as thier name, grade in school, favorite McDonald's food, favorite sport, and favorite book. After the letter is sent in, a response is sent back thanking the child (Mifflen,1997,5).


Other Web sites target kids by try to build relationships with them. They try and get children to remember thier brands and build brand loyalty. Brand loyalty is an extremely important concept for advertisers, because most people who are loyal to one brand generally do not switch to other brands very easily. This gives companies a greater incentive to bombard people with ads when they are young and still forming their opinions. Some sites aim to build brand loyalty by offering games for children to play, while making sure that the product or the trademark is a noticable part of the game. Such is the practice at the Kelloggs site where after kids give thier e-mail address, they can hang out with gang from the Rice Krispies cereal in thier club house. Kid's can "Chill with Crackle! in the Rec Room," "Party with Pop! in the Lounge", or "Slide with Snap! into the kitchen (CME-Sponsor,1)."


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Why We Should Be Worried


What, Me Worry?

Kids now days are looking up cyberporn on the internet and you're telling me we should be worried about a few ads directed at a few kids? Yes,I know it sounds like we are making this problem into something bigger than it is. But the implications of a few ads now grow even more dangerous in the future. The dangerous part of these hidden advertisements are the same reason the internet is so popular -- the level of interactivity that you can achieve on-line. This interactivity gives companies the power to find out exactly what a little boy or girl's likes and dislikes are and then capitalize on them by tailoring thier Web travels to thier individual interests. And unlike TV, radio, or, print advertisements, the World Wide Web can illicit an immediate response from someone.

Children are also susceptible to these ads because many times they cannot distinguish that they are being exposed to Web ads, because the advertising is not in it's pure form. Sometimes it's just having the product's characters play games with the child, but the trademark is always visible. And we all know the effects that the ads based on Saturday morning cartoons have on children. An advertisement is at most sixty seconds long. Imagine a Saturday morning cartoon that is an advertisement and that can tailor its message specifically to meet the child's needs and wants. This is what the internet is capable of.

Another suprising aspect of the internet is the lack of regulations that are imposed on content on the internet. Many internet supporters are afraid that censoring what people can and cannot put on the Web would stifle its growth. And it most assuredly will. But advertising has always been a different issue, especially when censorship issues are raised. Advertisers do not enjoy the same free speech rights that normal citizens do. There are rules against deceptive and unfair advertising that apply to print media, radio, and television. These same restrictions should also apply to the internet. Since these restrictions are not firmly in place, companies have found ways to manipulate the system and find an audience for these controversial ads.


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What Regulatory Agencies Are Doing About It


There are three main players in the fight against deceptive advertising on the Web. These three organizations are The Children's Advertising Review Unit (CARU), The Center for Media Education (CME), and the Federal Trade Commission (FTC). While CARU and CME do have major influence in how issues concerning this topic will turn out, only the FTC can enfore the rules and regulations that companies must abide by. These rules must first be made by Congress, which is being lobbied by these agencies to take action.

CARU has been working on protecting children under 12 from on-line advertising since 1995 and just released a set of guidelines in April of 1997. CARU is part of the Better Business Bureau and hopes that through self regulation the industry's growth will not be hindered (Macavinta,1997,p.1). A few of the guidelines that CARU proposes are:

  1. The use of cartoon characters, "kid's club" sites, and interactive games, to sell products over the Net without first disclosing that the site is advertising is prohibited.
  2. Interactive sites should remind children to get parental permission before collecting personal information.
  3. On-line sites that have ordering instructions should also remind children to get thier parent's permission before making a transaction(Macavinta,1997,p.1).

CME has taken a more proactive stance on the issue, by pushing Congress and the FTC to set up strict guidelines concerning on-line advertising. They have sent various letters to the FTC, outlining Web site practices that it deems unfair and urging the FTC to take action. They have also done thier own research on the issue, investigating some Web Sites that it felt were unfairly targeting children and reporting these sites to the FTC for review. These reports and studies produced a very influencial report released on March 28,1996 called "Web of Deception: Threats to Children from Online Marketing." Since then they have been a major proponent in the fight against unfair on-line practices directed at children, more so than CARU, whose stance is somewhat on the soft side. Although CME agrees with CARU's recommendations, they feel that those guidelines are not strict enough, according to Jeff Chester, the executive director of the Center for Media Education.

"We applaud the fact that the industry is still trying to address the problem, but their guidelines are inadequate. Just having a on-line disclaimer that tells kids to tell their parents first is not going to work (Macavinta,1997, p.1)."


These are a couple of the guidelines that CME proposes:
  1. Collectors and Trackers of information must get parental permission in writing, with full disclosure on why the information was collected and how it will be used.
  2. Web Sites that collect information from children must "provide a process for preventing further use of personally identifiable information previously collected"(CME-Guidelines,1997,p.5).

The FTC has proposed several guidelines as well, but has taken a lassiez-faire attitude on enforcing them, mainly because after public attention has been brought to a Web site, the offenders have revised the site to conform to the guidelines. The FTC investigated one such site, called KidsCom, at the urgings of the CME. KidsCom was one of the first Web sites specifically targeted toward children. Shortly after the review, the Commission decided not to take action against KidsCom because it had modified its site to fit some of the guidelines. The KidsCom Web site now has the "Ad bug", a cartoon bug that is supposed to show up anywhere on the Web site where there is an ad. It also reminds kids to get their parents permission before giving the personal information needed to register on the site. Registering on the site gives kid's unrestricted access to all the games and contests run on KidsCom. The Commission now acknowledges that the collection of information from children on the Web is widespread and says it will monitor such practices in the future.


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Web Sites That Decieve


So, it has been established that there are sets of rules that marketers and advertisers should follow when attempting to collect information from children. What has not been cleared up is whether a site that tries to build up brand loyalty by creating a branded enviroment where kids can play games is a form of unfair advertising. Until someone comes up with a strict definition of on-line advertising, children will be able to play games with Toucan Sam, watch the M&M's do a screentesting of hamlet, or Send e-mails to Ronald McDonald.

Whatever it is, it is directly targeted at kids, and it's not going to go away any time soon.

These are some of those Web Sites. You decide for yourself -- Harmless fun and games, or Sneaky Advertising?


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Steve Lovstrom Productions, Inc. Last Revised: 4/14/98 Questions? Comments? Concerns? E-mail me at spld@ufl.edu