CARU West Coast Conference Focuses on Children’s Online Behavior

May 23, 2011 | On Wednesday, May 18th, the Children’s Advertising and Review Unit (CARU) hosted the 2011 Children’s Advertising and Online Privacy Summit in Universal City, California.   The event, CARU’s first West Coast conference, focused on children’s online behavior and corresponding actions to assure that youth remain safe.   Attended by nearly 100 persons, the session included strong representation from the toy industry – both toy companies and licensors were present, as was TIA staff.

During her keynote address, Anastasia Goodstein, Director of Digital Programs at the Inspire USA Foundation, delved into the “Secret Lives of Tweens Online” and explained that this group WILL talk about everything that is going on in their lives.  This means any “youth community” (e.g., organization that has an online presence targeted to this audience) must be prepared with technology that will limit open disclosure for kids age 12 and under, and - for audiences over 13 – have an appropriate crisis response plan for the sensitive issues that can arise in an open dialogue.

Research presented during one of the panel discussions indicated that nearly 40% of children reported that they were online during a typical school day (weekday) … but the awareness by these kids of Internet ads was practically non-existent when compared to other types of advertising (from television to print). 

“The question is not whether the ads are being noticed by kids, but whether the ads are being confused with content,” said one panelist. 

During one of several references to advergaming made throughout the day, panelists agreed that many kids want to see product placement in games because it makes the experience more lifelike:  “The more real the experience … the more entertaining it is.”

During a later discussion, advergaming was described as: “when you’re really trying to sell something” but including a recognized character in a game does not itself constitute advergaming.

A consistent theme throughout the day was the importance of enhanced parent education. “If parents don’t step in, there’s really not much we can do,” said a panelist.  During a later discussion, Katie Harrington-McBride of the Federal Trade Commission referenced OnGuardOnline.com, the Commission’s online parental education program that offers tips on protecting kids’ privacy online, and its Parent’s Guide to Social Media.

Responding to requests for updates on the recent review of the Children’s Online Privacy Protection Act (COPPA), Ms. Harrington-McBride confirmed that “within the next few months there will be an articulation from the FTC in which the Commission will either announce that there will be no change OR that there will be an announcement of what the changes will be.”

Many present supported the need for online privacy regulations and best practices to evolve to keep pace with changing technologies.  One example cited was the rampant posting of photos to social media sites, making online images the latest recognized form of Personal Information (PI).  Other subjects broached were online behavioral advertising (OBA) and the FTC’s “Do Not Track” proposal.  Several panelists agreed that the need for best practices would likely trump the need for regulations because “the regulatory practice takes too long and by the time regulations are approved the technology has already changed.” 

When addressing the subject of marketing in the new media age, the FTC reiterates that the same advertising rules apply regardless of medium or venue.  “A violation is a violation.  The medium or venue or size of organization doesn’t matter,” said Ms. Harrington-McBride, who did reiterate, however, that the FTC is working hard to make sure its online resources are comprehensive and easy to understand – especially for smaller businesses.

The Summit touched on a number of related issues regarding product placements in online games, movies and television programming, product tie-ins with food marketing campaigns, and sweepstakes and contests. 

TIA staff reiterated the toy industry’s request that CARU ensure its guidelines accurately reflect current technologies and that its self-regulatory guidelines be regularly maintained to keep pace with change. TIA members will be kept apprised as additional information becomes available.



Communicating to Kids – Responsible Online and Offline Advertising, a one-hour webinar presented by CARU staff, will be hosted by TIA on June 22, 2011.  This session will provide TIA members and others in the youth marketplace with an introduction to CARU and “must-have” information on new guidelines, emerging issues and relevant laws regarding any type of advertising or marketing outreach to young consumers. It will also include a brief introduction to children’s online safety as related to toys and games as well as related to ongoing communications between children and toy and game providers and media literacy – including the blurring of editorial and advertising content.

Additional information about CARU can be found on the TIA website under the heading “The Toy Biz” and the subheading for “Responsible Marketing to Children.”