This document discusses ethical online engagement with young people and families. It provides an overview of the current digital environment and behaviors of young consumers. It then outlines various regulations and legislation regarding marketing to children, including restrictions around harming children physically or mentally, deception, disruption of parental authority, and data collection. The document notes both opportunities and challenges ("good, bad, ugly") in digital engagement. It emphasizes remembering guidelines, being creative and unique, providing value and enjoying content, and generating advocacy through earned media.
15. The digital footprint of a young consumer
• 80% of children (7-16) use the Internet at home and 40% have their own computer
• 90% of young people (11-16) have their own mobile phone
• A large majority 87% also own a games console
• Time online is heavily dominated by communities, chat, games and entertainment
• Most of these sites are commercially owned (with the exception of the BBC)
Source: The Buckingham Report
16. The digital footprint of a young consumer
Source: ICT at the School and in the home: efficiency, inclusion and digital skills
17. The digital footprint of a young consumer
• 78% interactive whiteboard coverage in UK (US = 28%, worldwide = 7%)
• 80% of all UK schools e-enabled by 2014
• 80% of teachers positive toward ICT (KS1, KS2, KS3 and KS4)
• 83% (86%,80% primary,secondary) use technology in lessons for creative purposes
• 76% (76%,68% primary,secondary) use technology in lessons for problem solving
Source: Harnessing Technology for Next Generation Learning, Becta
18. The digital footprint of a young consumer
Source: ICT at the School and in the home: efficiency, inclusion and digital skills
25. Further issues…
• No fixed definition of a child
• Current guidance can’t keep up with rate of change
• Blurring of geographical boundaries
26. What can we do about this?
• Follow the spirit of the guidelines throughout all communications
27. Making sense of the rules
• Marketing communications addressed to children must contain nothing that
is likely to result in their physical, mental or moral harm. CAP code 5.1
• Children must not be encouraged to enter strange places or talk to strangers. CAP code 5.1.1
• Products unsuitable for children or young people should not be advertised in media targeted to them, and
advertisements directed to children or young people should not be inserted in media where the editorial matter
is unsuitable for them. ICC Article 18
• Websites specifically aimed at children should ensure that content on their site is suitable for their audience.
Sites should ensure that they offer navigation which does not lead younger users from content which is
suitable for them e.g. on a general portal’s home page, directly to content which is clearly unsuitable.
Home Office Best Practice
• Users of children’s sites should be clearly informed when they are about to move to third party content.
Home Office Best Practice
• Message and bulletin boards aimed at children may wish to pre-moderate all user-generated content so that
all material is seen and checked before it is published; and provision of a post-moderated service if the service
is aimed at older children where messages will be removed by a moderator once published, if the posts are
clearly in breach of house rules. Home Office Best Practice
29. Making sense of the rules - damage
• Marketing communications addressed to children must contain nothing that
is likely to result in their physical, mental or moral harm. CAP code 5.1
• Children must not be encouraged to enter strange places or talk to strangers. CAP code 5.1.1
• Products unsuitable for children or young people should not be advertised in media targeted to them, and
advertisements directed to children or young people should not be inserted in media where the editorial matter
is unsuitable for them. ICC Article 18
• Websites specifically aimed at children should ensure that content on their site is suitable for their audience.
Sites should ensure that they offer navigation which does not lead younger users from content which is
suitable for them e.g. on a general portal’s home page, directly to content which is clearly unsuitable.
Home Office Best Practice
• Users of children’s sites should be clearly informed when they are about to move to third party content.
Home Office Best Practice
• Message and bulletin boards aimed at children may wish to pre-moderate all user-generated content so that
all material is seen and checked before it is published; and provision of a post-moderated service if the service
is aimed at older children where messages will be removed by a moderator once published, if the posts are
clearly in breach of house rules. Home Office Best Practice
30. Making sense of the rules - deception
• Marketing communications addressed to children must not exploit their
credulity, loyalty, vulnerability or lack of experience. CAP code 5.2 (is this one law)
• Children must not be made to feel inferior or unpopular for not buying the advertised product. CAP code 5.2.1
• Children must not be made to feel that they are lacking in courage, duty or loyalty if they do not buy or do not
encourage others to buy a product. CAP code 5.2.2
• Adult permission must be obtained before children are committed to buying complex or costly products.
CAP code 5.2.4
• Marketing communications addressed to or targeted directly at children must not exaggerate what is attainable
by an ordinary child using the product being marketed. CAP code 5.3.1
• Marketing communication directed to children should be clearly distinguishable to them as such. ICC Article 18
• Children can be vulnerable to advertising that is not clearly marked as such, for example advertising which
appears to be editorial content. Advertising can also exploit children through their lack of experience and
maturity. Home Office Best Practice
• Marketing communications must not falsely claim or imply that the marketer is acting as a consumer or for
purposes outside its trade, business, craft or profession; marketing communications must make clear their
commercial intent, if that is not obvious from the context. DMA 2.3
31. Making sense of the rules - deception
• Marketing communications addressed to children must not exploit their
credulity, loyalty, vulnerability or lack of experience. CAP code 5.2 (is this one law)
• Children must not be made to feel inferior or unpopular for not buying the advertised product. CAP code 5.2.1
• Children must not be made to feel that they are lacking in courage, duty or loyalty if they do not buy or do not
encourage others to buy a product. CAP code 5.2.2
• Adult permission must be obtained before children are committed to buying complex or costly products.
CAP code 5.2.4
• Marketing communications addressed to or targeted directly at children must not exaggerate what is attainable
by an ordinary child using the product being marketed. CAP code 5.3.1
• Marketing communication directed to children should be clearly distinguishable to them as such. ICC Article 18
• Children can be vulnerable to advertising that is not clearly marked as such, for example advertising which
appears to be editorial content. Advertising can also exploit children through their lack of experience and
maturity. Home Office Best Practice
• Marketing communications must not falsely claim or imply that the marketer is acting as a consumer or for
purposes outside its trade, business, craft or profession; marketing communications must make clear their
commercial intent, if that is not obvious from the context. DMA 2.3
32. Making sense of the rules - disruption
• Marketing communications addressed to children must not actively
encourage children to make a nuisance of themselves to parents or others
and must not undermine parental authority. CAP 5.4.1
• Marketing communications addressed to or targeted directly at children must not include a direct exhortation to
children to buy an advertised product or persuade their parents or other adults to buy an advertised product for
them. CAP 5.4.2
• Marketing communications that contain a direct exhortation to buy a product via a direct-response mechanism
must not be directly targeted at children CAP 5.5 2010
• Promotions addressed to or targeted directly at children must make clear that adult permission is required if a
prize or an incentive might cause conflict between a child’s desire and a parent’s, or other adult’s, authority
CAP 5.6.1 2010
• Prices should not be presented in such a way as to lead children and young people to an unrealistic
perception of the cost or value of the product. ICC Article 18
• Marketing communication should not imply that the product being promoted is immediately within the reach of
every family budget. ICC Article 18
33. Making sense of the rules - disruption
• Marketing communications addressed to children must not actively
encourage children to make a nuisance of themselves to parents or others
and must not undermine parental authority. CAP 5.4.1
• Marketing communications addressed to or targeted directly at children must not include a direct exhortation to
children to buy an advertised product or persuade their parents or other adults to buy an advertised product for
them. CAP 5.4.2
• Marketing communications that contain a direct exhortation to buy a product via a direct-response mechanism
must not be directly targeted at children CAP 5.5 2010
• Promotions addressed to or targeted directly at children must make clear that adult permission is required if a
prize or an incentive might cause conflict between a child’s desire and a parent’s, or other adult’s, authority
CAP 5.6.1 2010
• Prices should not be presented in such a way as to lead children and young people to an unrealistic
perception of the cost or value of the product. ICC Article 18
• Marketing communication should not imply that the product being promoted is immediately within the reach of
every family budget. ICC Article 18
34. Making sense of the rules - data
• Marketers must not knowingly collect from children under 12 personal
information about those children for marketing purposes without first
obtaining the consent of the child’s parent or guardian. CAP 10.15 2010
• Marketers must not knowingly collect personal information about other people from children under 16.
CAP 10.16 2010
• Risks to children may arise from the misuse of their personal data. Children may willingly provide personal
information without being aware of the implications , for example, in order to enter competitions, and this
information can be open to misuse. Home Office Best Practice
• Websites should be careful about including photos, contact or other details, which together could serve to
make children identifiable and contactable. Home Office Best Practice
• Websites that collect information from children must have stronger safeguards in place to make sure any
processing is fair. . . The language of the explanation should be clear and appropriate to the age group the
website is aimed at. “If you ask a child to provide personal information you need consent from a parent or
guardian, unless it is reasonable to believe the child clearly understands what is involved and they are capable
of making an informed decision.” UK Data Protection Act 1998
