The Federal Trade Commission has been urged to subpoena research documents.
It may be far from happening, but as an indication of a growing grassroots frustration with online marketing, and many parent's fears, the Center for Digital Democracy (CDD), a public advocacy group, has written a letter to the Federal Trade Commission (FTC) chairman, Timothy J. Muris, and four fellow commissioners, asking for a review and analysis of the interactive marketing and branding technologies and techniques used by advertisers to target children in the US.
Specifically, the CDD requested that the FTC subpoena research documents and other evidence from online marketers and marketing agencies, research and audience measurement firms concerning the underlying "nature" of the techniques used to market to children and teens.
Stating that the "immersive, relational, and ubiquitous nature of such marketing raises serious questions about the ability of existing safeguards and rules to protect our nation's children and young people," the CDD urged the commission to obtain any needed documents, including proprietary research studies. The CDD also called on the ad industry to adopt a moratorium on all interactive techniques that -- in the absence of independent research suggesting otherwise -- could potentially harm or negatively affect children and youth.
CDD Executive Director Jeffrey Chester said the nation's parents, educators, and health professionals should be concerned about the impact that such digital technologies have on the psychosocial development of children. "We know that the advertising industry is wielding powerful new tools that track and target the 'behavior' of the online and interactive audience."
Clearly upset by the unknown nature of online advertising, Mr. Chester said, "How this marketing affects such critical developmental issues as cognition/brain development, identity formation, and the emotional system must be well understood prior to its use on the child-to-teen audience."
Similar concerns were voiced in the early days of television. But anxiety seems heightened today because of the one-to-one and personalized tracking claims of many online agencies and ad serving companies.
Are those claims true? As yet, no. And they may never be. But that does little to calm the type of fears raised by the CDD letter:
"...the architecture of our nation's electronic media system is in a critical
transition, with the widespread deployment of new data collection, profiling
and personalization marketing techniques."
"The advertising industry is engaged in multiple research efforts designed
to perfect their ability to pinpoint consumers online and to ensure that they
can be both tracked and measured."
As part of the CDD release, Michael Brody, MD, chairman of the Television and Media Committee of the American Academy of Child and Adolescent Psychiatry, wrote, "Interactive marketing to children exploits their cognitive weaknesses, and is a deceptive and shameful misuse of child development principals."
Whether or not these accusations are true, the online advertising industry cannot ignore them. But that may be what it is attempting to do.
In an article published by MediaPost, Michael Wood, vice president of research firm Teenage Research Unlimited (TRU), said, "No one has ever come to us, even from a parent perspective, with any horror stories."
According to the CDD letter, the "aggressive marketing practices" of digital technologies overstep the explicit limits of the Children's Online Privacy Protection Act of 1998 (COPPA), which state that marketers are prohibited from engaging in deceptive marketing practices when targeting children.
But in the MediaPost article Jeff Lanctot, VP of media for interactive agency AvenueA, said his company has never had any problem with COPPA. "We'll probably find that online is no more aggressive -- and probably less aggressive -- than other mediums," he said.
Maybe. But ducking the issue now may lead to trouble in the long run. Perhaps the online ad industry should heed the Boy Scout motto that young people have been learning for decades: "Be Prepared."
unknown, eMarketer.com. June 11, 2004
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