"Little Johnny likes Batman" – The Ethics of Facebook Advertising and Children

There have been several news articles in the past few weeks addressing issues of privacy and kids. From the Consumer Report’s findings that there are 7.5 million children under the age of 13 using Facebook, which is against Facebook’s own policy (read more), to California’s proposed Social Networking Privacy Act (SB 242), to the FTC’s investigation of Facebook’s possible COPPA violations (illegal advertising to minors). I have mixed reactions to all of this, but overall I am encouraged to see so much attention circulating around children and privacy. My dissertation research (which I’ll get around to discussing on here soon), focuses on children, digital media, and perceptions of risk. It seems far too often media and policies pay too much attention to harmful yet unlikely risks (such as predators) and tend to neglect the less harmful yet significantly more likely risks (such as invasion of privacy). Thus I see the invested interest in privacy to be a positive pendulum swing with regards to children, risk, and digital media.

I am not at all surprised there are so many “under age” children with Facebook accounts. Social media have become increasingly popular with all age demographics, and young children are no exception. Facebook attempts to restrict its site to 13 year olds however, any child can lie about their birthdate and sign up for an account. To be honest, this doesn’t bother me that much in and of itself. The purpose of Facebook’s minimum age requirement is not safety-driven but rather privacy-driven. Facebook’s minimum age requirement is in compliance with the 1999 Child Online Privacy Protection Act (COPPA) which is intended to protect minors from unknowingly releasing too much personally identifiable information (PII). The Act aims to give parents control over how much information is collected from their children online. However, because Facebook is not aimed at children under the age of 13 (hence the minimum age requirement), they have not had to abide by the same COPPA requirements. But this could change…

Facebook is facing several lawsuits from residents in New York and California because of possible COPPA violations. Facebook’s Terms of Service state that the site may use users’ names and images to promote brands that they have “liked” on Facebook. While many adults view this as a privacy violation or an unethical form of advertising, users agree to it when they sign up for an account (and can restrict this to a certain degree via privacy settings). However, this becomes a gray area when the user is under the age of 13 and Facebook did not obtain parental consent to use their child’s name and image – hence the lawsuits. On the one hand I completely agree that parents should have to give consent for commercial websites to use their child’s name and image for advertising purposes. However, I’ll be interested to see what the courts decide since said users were clearly violating Facebook’s Terms of Service when they lied about their age. In so doing, did they waive their COPPA rights by lying about their age?

This gray area highlights some interesting aspects of children and social media. The Consumer Report article finds it “troubling” that so many “under age” kids have Facebook profiles. While the article does mention privacy concerns, it also discusses other risks such as bullying, exposure to pornography, and mallware. The article says,

“Parents of young children might think they are less likely to take risks, some observers say. “It’s like an alarm clock goes off for parents when their kids turn 13,” says Vanessa Van Petten, creator of Radical Parenting, a blog featuring writing by teenagers that aims to improve family relationships. “Parents think their younger kids aren’t interested in porn. With a 10-year-old mentality, they’re only interested in 10-year-old things.”

But those parents would be mistaken. Ten-year-olds need protection from other hazards that might lurk on the Internet, such as links that infect their computer with malware and invitations from strangers, not to mention bullies.”

Interesting how quickly the conversation shifts from concerns of privacy to concerns such as pornography. This is a really bizarre quote since ten year olds are highly unlikely to find porn on Facebook. Facebook has a strict policy regarding porn, nudity, and even sexuality (evidenced by controversies over Facebook removing photos of a gay kiss and breast feeding). Pornography really doesn’t belong in a discussion about children and Facebook. I find it interesting how often Facebook’s minimum age requirement is interpreted as a mechanism to protect children from the big scary world of the internet when in fact it has nothing to do with porn or bullying, but rather privacy and advertising.

I do agree with the Consumer Report that parents should also be concerned about their younger kids online (not just tweens and teens), however I find the tone of the article to be a bit alarmist and dismissive. Just because parents of younger children aren’t closely monitoring their Facebook accounts does not at all imply they are not monitoring their kids’ use of the internet in general. Of all the websites a 10 year old might purposely or accidentally access, Facebook is definitely not the riskiest.

Another aspect of all of this that I find interesting is the increasing number of younger children who are using Facebook. Facebook obviously started as a college-aimed website and has expanded to a much larger demographic, but I don’t think even Facebook really considered the appeal it would have for elementary aged children. This makes me question whether or not Facebook should really be excluded from COPPA requirements. If there are more than 7.5 million children under the age of 13 using Facebook, then doesn’t that demonstrate that Facebook appeals to children? Rather than deleting these accounts, wouldn’t it make more sense for Facebook to comply with COPPA? This would discourage children from lying about their age and require advertisers to meet COPPA standards when engaging with children’s information. I recognize that Facebook is successful because of “social advertising” and too harshly restricting what advertisers can do with users’ information would be detrimental to Facebook’s successful business model. However, the cat is out of the bag and children are going to continue to use Facebook regardless of policy. Thus, I think Facebook should allow young children to use the site and make sure that profiles under the age of 13 are COPPA compliant. This doesn’t threaten the overall business model of Facebook, it merely protects minors in a way that the current system fails to do (since users are encouraged to lie about their age).

As noted, I’m glad to see privacy once again moving to the forefront of children and protection debates. As I’ve discussed before (here and here), privacy is a very important issue when it comes to new technologies, and certainly something we should be concerned about in regards to children. I don’t have all the answers, but I’m definitely in favor of sites such as Facebook (and their advertisers) being held accountable for their engagement with children and children’s personal information.

One thought on “"Little Johnny likes Batman" – The Ethics of Facebook Advertising and Children

  1. I think it is the responsibility of the parents to check if their kids are using Facebook. In the first place it clearly states in their usage policies that they do not allow underage kids to use their site. So how can parents protect their kids from these ads? Do not let them use Facebook.


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