Google's plans to target kids with marketing and ads/Strong safeguards required/Must demonstrate corp. responsibility
By: Jeff Chester | Aug 20 2014
Whether a scoop or a purposeful leak to the The Information online news site in order to gauge political reaction, Google's plans to begin micro-targeting children 12 and younger is a critical public policy and child welfare issue. As the leading digital advertising company--which is what Google really is--how it ensures that children are fairly treated in terms of their privacy and by the impact of the company's powerful data-driven targeting machine is incredibly important to those of us who care about children.
For those that may not know, my wife--Professor Kathryn Montgomery of American University--and I led the campaign that saw the Children's Online Privacy Protection Act (COPPA) enacted into federal law in 1998 [while we both directed the NGO Center for Media Education]. It was clear to both Kathy and I as early as 1994-95 that personalized and pervasive digital marketing would be at the core of the Internet's future (for more on this period and why we needed COPPA and other privacy safeguards, read our books that address this period). Since the law went into effect in 2000, my CDD has been the key group working on COPPA, including our very successful campaign involving many leading consumer groups that led to the FTC's 2012 decision that expanded its set of safeguards. COPPA now empowers parents of children 12 and under to make meaningful decisions on data collection from children on multiple platforms, including mobile and gaming, as well as with diverse applications (such as Apps). These new FTC safeguards were required to address the continued and unchecked growth of personalized data collection and targeting of individuals and groups online that has been pioneered by Google and has been widely adopted worldwide.
Children may be growing up as "digital natives," as the online ad business likes to call them, but they aren't little adults. Indeed few people really understand how digital marketing works and what kinds of consumer protection, privacy and public health policies should be in force. At CDD, we have made it a key priority to closely examine what the online ad lobby euphemistically calls the digital marketing "ecosystem." One of the ways we have done this is to follow especially what Google does (as well as Facebook and other industry leaders and emblematic practices). Google's own track record on privacy, as well as its efforts to undermine privacy rules in the EU and elsewhere doesn't give any confidence it will, on its on, act responsibly here. After all, it had to agree to an unprecedented 20-year Consent Decree with the FTC because it didn't pay close attention to protecting user privacy.
We are convening a legal team of COPPA experts and have already sounded the alarm with leading NGOs concerned about children and privacy. CDD has also contacted the FTC. We will be proactively working to ensure kids are protected, parents given the tools they require, and that more than minimal COPPA compliance is provided by Google. It will need to demonstrate to the FTC, Congress, State AGs, child health and privacy groups that its approach to COPPA comprehensively addresses its real-time marketing apparatus.
In order to provide services to children, Google must demonstrate that it's giving parents accurate information on the data collection and ad targeting process; provide granular controls that enable meaningful parental privacy decision-making; separate data-drive marketing applications from children's content that impact their privacy and the choices a parent makes; create new ways for a child to participate without advertising, profiling and digital stalking (which Google, in a tip to George Orwell, has renamed "remarketing." The industry calls it tracking and retargeting).
Anyone who knows how Google really conducts its business should be alarmed about its plans to make money off of kids. No individual or group is immune to Google's interest in targeting them with ads, including whether they are on a mobile device, social network, watching YouTube, searching or even in a store. Google sells us regardless of platform, and encourages companies to target Hispanics, African Americans and others because of their brand loyality and buying habits. Google helps food and beverage companies sell unhealthy products to kids and works with the biggest global ad agencies to do so. "Big Data" tactics are regularly used by Google to track and target indivduals wherever they are online on behalf of its advertiser clients. Google helps its ad customers target us for financial products, health care and much more. It is also working to expand its reach into the school marketplace (which raises the links it could make with what a kid also does in school).
But Google has a problem. In order to continue to be the global digital marketing leader, it has to expand its monetizing (the industry term for making cash off us and our data) practices. Kids are the last nearly untouched market, since COPPA's opt-in and informed parental consent privacy requirements are a serious problem for Google and others who really don't want to respect our privacy online. Kids (so called "Generation Z" by marketers) are a very lucrative market, spending and influencing billions of dollars each year, including for games, apps and other products. Companies want to "brand" early and develop lifelong loyalty and, of course, ongoing spending.
Google is going to have to show it is truly creating privacy friendly products for children that isn't linked to its powerful digital marketing apparatus; that it won't target kids for junk food and other products that can harm their health (and have contributed to the global obesity epidemic); and that parents will have serious controls over the ad and data collection process. CDD will be there to help ensure it happens, in part by applying to Google's forthcoming COPPA compliant system an analysis based on that company's actual digital marketing practices.
Our recent guide for parents on Facebook's plans to open up its Big Data targeting system to children 12 and under is relevant to also understand Google's impact on their privacy and welfare.