Recognizing that children are fundamentally different from adults, are we as an industry obliged to modify our approach to targeting kids online? Is it necessary or even advisable to address the behavioral profiling implications and age appropriateness of certain kinds of targeting? I don’t know but would love to hear from the networks and publishers about how they work with advertisers whose target audience includes minors.
There’s a long history of acceptance of guidelines and laws in traditional advertising. The Children’s Advertising Review Unit (CSRU), a council of the BBB, offers self-regulatory guidelines for advertising to children that recognize the inherent differences in the way children consume and understand media. The Canadian Association of Broadcasters has a list of 10 commandments, its Rules for Advertising to Kids. PBS Kids devotes a portion of its site to teaching kids how to interpret the (mostly TV) advertising directed at them, and a slew of scholarly works have been written on the topic of kids and commercialism. This is by no means an exhaustive list of the laws and guidelines to which children’s marketers must attend.
Although most of us heartily endorse the Children’s Online Privacy Protection Act (COPPA) laws, COPPA serves a very specific purpose. COPPA laws protect children’s privacy by providing policies that affect the way sites can collect or use personal information. They also give parents some control over information on kids under 13. In cases where behavioral marketing results in a registration of any sort that includes personally identifiably information (PII), COPPA laws clearly apply. But they wouldn’t for a garden-variety behavioral targeting program. Does the mere act of targeting kids place a duty on advertisers to alter the way advertising is targeted or delivered? Should we think or act differently when behaviorally targeting kids?
Since we don’t currently have a panel at hand to debate the topic, I chose to imagine one. Since they’re imaginary, they have the luxury of being polarizing to make a point (and hopefully won’t get flamed as a result).
Con: We should be very careful in how we target kids. They don’t have the media maturity to understand why they’re getting all these ads that seem tailored just for them. Many of them may not even understand the difference between editorial content and advertising. It hardly seems fair.
Pro: I don’t know about that. Tweens, in particular, are very media and device savvy, much more so than earlier generations. Just because the technology’s more sophisticated doesn’t mean the intent or content is any different. If the ads would pass all the standard guidelines and laws, it shouldn’t be important how or why particular ads were served.
Con: But kids are naïve in so many ways. They need protection. Johnny doesn’t understand that just because he’s a rabid soccer fan and surfs related online content, certain ads are delivered to him. The ad content may seem too appealing because it caters to his interests.
Pro: So, serving kids ads on topics that are more likely to be of interest to them is a bad thing? To continue to enjoy the free content on their favorite sites, they’re going to see ads of some sort. Would you rather kids be served ads they’d never notice and have Johnny’s favorite content disappear for lack of funding, or suddenly become available only if he pays for it?
Con: I’d hope advertisers and publishers would self-regulate in recognition of the potential harm of overly aggressive selling to children. Just because Susie put something on a wish list or in a shopping cart at her favorite site, should we follow her around the Internet taunting her with ads till she can’t see straight?
Pro: Clearly, responsible advertisers don’t want to incite kids to harass their parents. Smart advertisers also don’t waste a ton of ad impressions on a recipient who doesn’t respond; we can cap frequencies to avoid those situations. But is this really any different than Susie seeing a TV commercial for that product several times during her favorite programs?
Con: It would be similar if we followed her from channel to channel, if we could recognize her when she returned days or weeks after she turned off the TV, or if we could customize the ads she saw to make them more appealing.
Like most complicated issues, this issue goes much deeper than this imaginary debate. Marketers are highly sensitized to treating children in age-appropriate ways, but rapidly advancing technology presents new challenges. Behavioral targeting offers tremendous flexibility in its focused targeting. The question is whether those capabilities should be used, and, if so, how they should be used in pursuit of the minds and buying power of children. Do we draw that line? If we do, where is that line and how do we draw it? Perhaps even more important, who draws it?
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