Full Disclosure?

Child Trends’ business is information about children. But information has taken on a new—and personal—meaning and importance in the digital age, when details can be broadcast more than ever before. Hand-in-hand with children’s increasing use of Internet-enabled devices, some businesses with an online presence specifically target children as consumers of services and products, and, in many cases, seek to collect personal information on those children. Businesses use this personal information to improve their marketing strategies, or to trade with other companies.

These practices raise red flags for parents and others who are believe that children deserve protection from those who might take advantage of their immature judgment or violate their privacy. Adults themselves often are challenged by the efforts of online marketers to gain a leg up on their customers; children cannot be expected to give what researchers and legal scholars call “informed consent.”

The Federal Trade Commission (FTC) has just issued a new update to the Children’s Online Privacy Protection Act (COPPA) that addresses the ever-expanding reaches of Internet technology, and reinforces the role of parents in controlling access to their children’s personal information. Some of this information-gathering is often obvious, but some (for example, tracking on-line behavior, or physical location) isn’t. The FTC’s new COPPA rules specify that any website or service that collects personal information on children younger than 13 must notify parents directly before doing so, inform parents how they will use the information, and get their “verifiable consent” before collecting information on their children. Parents must also be able to review their child’s personal information, revoke their consent, and delete that information.

At Child Trends, our staff is involved in many kinds of research, some of which collects information directly from children and parents; in other cases, we have been granted access to personal data others have collected. We take seriously our responsibility to protect the privacy of these individuals. When appropriate, proposed research must be cleared by our Institutional Review Board (whose mandate is to protect “human subjects”) before it can get started. Other safeguards we use include controlled-access computer servers and data rooms, locked file cabinets, and signed legal documents detailing our responsibilities in this area. We keep the information only for as long as there is a need to do so, and we dispose of it securely.

Children are more than simply “customers,” “consumers,” or players in the online social media space. Children merit protection, but need appropriate autonomy and responsibility, the balance of which is finely, and continually, negotiated by sensitive parents and other caregivers, and by the institutions and communities in which they participate. At Child Trends, we call this acknowledging “the whole child.”