Responsible Engagement with Children through Social Media
There is a real need to act responsibly and appropriately when engaging with children through social media. Social media is not going away and, to a large extent, children are the paradigm target consumer of social media. They are capable of consuming and engaging with a number of social media outlets at any one time.
As Dr Pepper found out recently when, as part of a Facebook campaign, one of its employees posted the name of an adult movie on a 14-year old girl's status, there is a real need to act responsibly and appropriately when engaging with children through social media. Social media is not going away and, to a large extent, children are the paradigm target consumer of social media. They are capable of consuming and engaging with a number of social media outlets at any one time.
Social media platforms can be very intrusive and pervasive, as they are always "on" and can be accessed whenever or wherever through smartphones. All Web 2.0 service providers must take great care when deciding, for example, what content and behaviour is appropriate in child-targeted advertising. It is an obligation that the industry takes very seriously, no doubt fearing the backlash if something were to go wrong. It is also one which the Government is keen to reinforce.
A host of extra-legal guidance has been created to map out what is appropriate in the online world. The Government have been pro-active, setting up the Child Exploitation and Online Protection Centre and producing good practice guidance in the form of the Home Office Task Force On Child Protection On The Internet. Any website based in the US (e.g. Facebook, Twitter) must comply with a piece of legislation specifically aimed at protecting children's online privacy.
As is typical in the UK, by contrast, an industry-led approach has been the preferred way of putting protection in place. The ASA has recently introduced additional rules on marketing to children and these rules will extend to all online advertising in March this year. The advertising industry has also produced The Children's Ethical Communications Kit which is an online tool which contains the legal requirements for a variety of marketing activities aimed at children. The central message, as set out in the CAP and BCAP Codes is that marketers must be sensitive to children's age, vulnerability and lack of experience.
More active moderation of content on user-generated forums might be desirable, potentially in combination with automatic screening tools set to raise alerts when "black-listed" words appear. Creating "pester power" is prohibited under the Codes and is a concern of the UK government but might social media engagement go too far down this line? All entities have obligations to hold and deal with personal data "fairly" but what is fair for adults might not be fair for children.
The UK's Information Commissioner has produced a "good practice approach" to these issues. Are the uses to be made of the data made clear in a way to the users, remembering that children users will have different levels of maturity? Should you obtain the parents’ verifiable consent for the child to give personally identifiable information (e.g. home address, email, phone number etc) to the site? The ASA's Codes now stipulates that marketers will not be allowed to collect personal information from children under 12 without obtaining the consent of their parents or guardian. Do you need to ensure that children are not allowed to post such information (phone number, address, first/last name), e.g. on a profile or through chat?
The Government clearly does not think that these developments provide enough protection and has recently set up an independent review into the commercialisation and sexualisation of childhood. A report is due in May 2011. The Minister responsible has expressed her concerns about marketing practices that are being used specifically to target children and has asked for specific recommendations on what can be done to address them.
Standard setting can only go so far, however. Realistically, children will want to explore the online world and develop their relationships within it, taking their real world curiosities and naivety further and into riskier territory than was possible a generation ago. For example, the industry recognises that children can sometimes easily avoid age based entry restrictions. The role of parents and the industry in general is, therefore, central to educating their children that behaviour that would be foolish in the real world may well be even more dangerous in the online world. You wouldn't give your mobile number out to a stranger on the street, for example, so why display it prominently on the Internet?
The stereotypical idea that parents do not or cannot understand what services are available to their children might be outdated, given the percentage of users of social media websites who are adults. The Government has, in fact, spoken of the need to equip parents to deal with the changing nature of marketing, advertising and other pressures that are aimed at their children. Securing parents' buy-in to a company's social media activity should be a vital part of acting responsibly towards juvenile users. For example, how well does a site communicate to an interested parent what their child might be involved with if it uses those services? Parents themselves can also be pro-active, using services such as AOL's tracking service, if they have the appetite.
Social media relies on engagement and engagement will only be effective and trusted if the providers act responsibly and if the audience (or at least their parents) understand the best way to act in the Web 2.0 world.
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Adam Rendle
Read about how and why social media operators targeting children should act to avoid backlash from regulators and parents.
"Do you need to ensure that children are not allowed to post such information (phone number, address, first/last name), e.g. on a profile or through chat?"
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