FTC: Consumer Privacy Comments Concerning Drs. Sharon Strover/Texas Telecommunications Policy --P954807
Federal Trade Commission
June 10-13, 1997
Children and the Internet: Parental
Submitted by Drs. Sharon Strover, Ellen
Wartella, Pat Stout and Jef Richards
Overview of Comments
The Texas Telecommunications Policy Institute is a newly-created policy institute at the University of Texas that addresses contemporary telecommunications issues. We undertake various research projects in order to provide data relevant to the policy process, with a special focus on educational, health-related, and library-related information issues. The Institute has faculty affiliates from around the University in fields as diverse as economics, advertising, engineering, communications, public affairs, and library and information science; it also has a public agency affiliate group representing various public agencies active in setting information policies and in implementing data-gathering and data dissemination programs. We are pleased to participate in the FTCs privacy workshop since one of our current projects provides information that has some bearing on its core questions.
The comments reported here are based on preliminary data from a project that is mid-way in its progress. We offer it in the spirit of sharing some tentative observations so that this forum might be spurred to ask the best questions and incorporate perspectives that have not yet received very much research attention. The Federal Trade Commission workshop session addressing children will be faced with a genuine dearth of relevant data. While our work is incomplete, we believe its early shape suggest some useful points.
We plan to address two question areas of the third component of the workshop:
Nature of the Research
Our research has four different modules, only two of which we will use in these comments. First, we are content analyzing several Internet sites targeting children. We used a snowball sample to generate the URLs in our database; consequently, it contains sites that are sponsored by educational (.edu), commercial (.com), institutions as well as non-profit organizations (.org). For the analyses reported here, we singled out 51 commercial databases. At this stage our database focuses on commercial sites that are not under the Compuserve, AOL or Microsoft domains. While these services are very important and have taken some first steps toward actively developing high quality childrens sites and offering some privacy protections, our analysis of them will occur in the next few months.
We recognize that any attempt to analyze Internet sites must acknowledge that sites change often and that many leave or enter the Internet domain. Site content is essentially a moving target. Nevertheless, we offer the findings reported below as a snapshot of typical sites during the early months of 1997. Appendix I contains our codesheet for the content analysis.
The second component of the data reported is focus group material. We have conducted focus groups with 15 parents of a combined total of 21 children who use the Internet. Our discussions with them covered what their children use the Internet for, what their parental concerns are, how they deal with privacy matters, how they interact with their children about their Internet concerns, and so forth. Appendix II contains the questions used in the focus group protocol.
This research has been underway since February, 1997. We anticipate conducting additional focus groups with parents, completing out Internet site content analysis, and conducting interviews with Internet Service Providers (at this writing, they have some liability for minors exposure to indecent material under the Communication Decency Act) and Internet content providers creating sites for children. The research team is composed of people who are specialists in children and media, advertising, and telecommunications and Internet research. The principal investigators include faculty from the Departments of Advertising, Radio-TV-Film as well as the Dean of College of Communication at the University of Texas.
Internet sites targeting children: a content analysis
Session Three: What kinds of personal information are collected by childrens commercial Web sites from children who visit those sites?
Response: We have analyzed 84 Internet sites offering content directed at children, 51 of them commercial Internet sites. As pointed out above, these were sampled in an unsystematic fashion, but do represent some logical paths that children might follow in pursuing different Internet links.
Of the commercial sites, we found 30% of them used advertising and nearly half (21) offered some sort of interactive service or component. Only about 10% (6 sites) had chat rooms, although we believe more and more sites are adding these features.
Very few (only 4) posted policy or use guidelines that might mention privacy and disclosure. About one-fifth of the sites had areas for parents, sometimes with links to safety information. For example, array.4kids.com has a long list of sites with information for parents about children and the Internet, as well as sites that are parenting resources. Five sites (10%) offered explicit safety tips.
Of the commercial sites, about half (24) requested no information at all from users. About 31% of the sites required registration for some activities - chat rooms, registration for product contests, matching people up for e-pals, and so forth. Only a handful (4) requested rather than required similar information. When such information is requested or required, it usually entails the individuals name (17 sites), email addresses (14 sites), and geographic information (7). Only a few sites requested age (6), date of birth (2), phone numbers (5), school information (2), or information about parents (3). Four sites requested information about consumer habits.
Session Three: What research exists about parents perceptions, knowledge, and expectations regarding childrens personal information being collected by site operators? What are parents perceptions, knowledge, and expectations of the risks and benefits of using "privacy" technology?
Response: A response to the issue of what parents believe and expect about information being collected from their children is to some extent contingent on what they believe their children are doing on Internet sites. Our focus groups suggest that parents are able to and often do monitor their childrens home use of computer and Internet sites, and that there are age-related differences in what children do on the Internet. Our sample included parents with children as young as 5 and as old as 19.
Young children who are not able to read or spell or type well (roughly under 10 under old) need assistance from adults in order to use Internet or other network sites. Therefore, when at home or at libraries these children have parents nearby or sitting with them as they search for different resources. As one man pointed out, "since most of this stuff is done at the library, and he [7 year-old son] doesnt go to the library by himself, then Im pretty much there all the time...to watch what hes doing. And hes still at the stage where he wants a lot of pictures and a whole lot of text." Younger children tend to prefer game sites and sites that feature favorite book and movie characters (often one and the same), and are oriented to pictorial sites rather than those with a great deal of text. Examples of sites mentioned included Sega game tip locations, Disney, and favorite book and movie/TV characters such as the Power Rangers and James and the Giant Peach.
Older children are more interested in interactive sites, especially chat rooms, as well as sites that might offer information on highly specific personal interests (Japanese animation, rock groups, music, school projects, etc.). Some parents mentioned that their children - boys especially - download games or game demos from the Internet.
Insofar as most children have access to email and the Internet through their parents accounts, it is easy for parents to see the sort of interactions and activities that children undertake on the computer. That said, the parents in our focus groups believed they had clear ideas about what their children were doing on the Internet. They could check the files and read their childrens email, and they frequently did both. Some of their motivation in doing so had to do with the routine computer maintenance, but they generally felt they had the right to monitor their childrens Internet behavior as well.
When asked whether they had any anxieties about their childrens Internet use, most parents responded with stories focused not on commercial information collecting worries but rather with stories focused on either concerns about their childrens exposure to indecent content or worries about their children meeting someone over the Internet. ("I think the stories that scare me are the ones where kids are seduced over the Internet by strangers in whatever manner. And that can happen in a public setting, so I guess its not necessarily an Internet issue, although it can happen more covertly over the Internet and it seems more insidious because it might seem pretty innocent initially.") In that sense then, the "privacy" technology that interested them was net "nanny" software that could keep their children from certain sites. Even so, there was some sentiment that this software could be defeated easily by their children: "...a 17-year old friend of [my childs] figured out what his dads password was and just totally disabled the nanny. It took him about two hours."
However, the members of these focus groups also felt that the best solution to Internet threats was to extend the lessons they give their children about everyday encounters in the physical world to encounters in the cyber world. That is, they felt that the same or similar precautions their children would exercise in releasing information about themselves to any stranger or service should apply whether the environment is the shopping mall, the telephone, or the Internet. One parent stated: "...as long as she sticks to the one
standing rule that I have, which is dont give out your address to people you dont know, she [her child] can do anything that she wants to do [on the Internet], basically and she seems to be just fine for that;" another mother commented; "I feel like everything Ive taught her about street smarts just in her own neighborhood she...weve tried to apply it to the Internet, and Im not really nervous about anything right now. Im sure something will come up, but I think shell talk to us about it.")
When asked explicitly about Internet sites that requested children register, most parents conceded they did not think their children would ask them about it, although some had rules prohibiting their children from giving out their home address and phone number. Five commented that it was clear when their children had signed up with a commercial site because they would receive "junk" email advertising a product (movie releases, etc.), and several discouraged registration because they did not want email from commercial companies arriving at their addresses. One commented "...Ive done some marketing work and you dont know where that information ends up, you just have no idea."
Most of the parents were only vaguely aware of "cookies" and how they functioned. One participant in a group was able to explain cookies with great detail, and the other members seemed keenly interested in this. This suggests to us that parents are only somewhat familiar with what information may be gathered from Internet search behaviors, and while they do not want unsolicited email arriving in their boxes, they see it as only mildly irritating and not a privacy per se. However, their unfamiliarity with the nature of the data being gathering during online interactions - theirs as well as their childrens - hints at the need for better information to be both available and obvious to parents. They may well feel greater concern if they were aware of what was being collected by the sites.
Session Three: Do childrens information practices in the online context differ from those implemented in other contexts?
Response: Based on reports from our focus groups, childrens information practices in the online context are very different from those in more focused settings such as schools or libraries. The online setting allows children to play, to seek entertaining material and interactive experiences. The opportunities for what is role-playing in one context or deception in another are clear - and it appears that older teenagers active in chat situations regularly experience both. Fundamentally, however, our parents noted that the online environment may function quite differently for the child in the home environment than it does in the school environment. In the latter, it is expected that children work on school-related projects. In the home environment however, more play and exploration are expected and indeed encouraged.
Because information-seeking in the school context is generally goal-driven and the available resources pre-selected and approved, there is less likelihood that children will be exposed to objectionable content or to invasive personal data-gathering practices. The online environment, however, is open to either deliberate or inadvertent information seeking practices that can deliver objectionable content; some of those practices also may entail gathering individual data via registrations. Most parents commented on the several positive aspects of their children using online information: the computer and Internet mode encouraged their typing and spelling skills; certain transactions help children to construct full and better sentences, and to learn how to undertake research; and their is a wealth of resources useful to school homework and projects and to individual hobbies and passions.
However, many parents also commented about negative aspects of the online environment: chat rooms are deceptive, too sexually oriented, and contain objectionable language; unsolicited email associated with childrens use of commercial sites usually was considered a disadvantage, particularly if the child shared the parents account (the typical practice). Some parents noted there is insufficient information on the Internet for younger children who lack good reading skills; additionally, they are afraid their children might believe automatically some of the things they read on sites or in chat rooms - that there are limited means to "test" the truth of certain sorts of information or exchanges. One mother of 15-year old girl recounted how her daughter and a girlfriend met two boys in a chat room and arranged a meeting with them at a local shopping mall. Although in this case the encounter worked out, shes aware of the chat room dangers - and allures. The same mother commented on chat rooms,"...you go on and you say youre a girl of a certain age, and you just get swamped by all these people who want to have private conversations with you, and it gets really gross really fast." Another mother stated "I think the chat rooms are the most dangerous places at this point, for being entrapped." Younger children are particularly vulnerable to deception.
For example, one father of a ten-year old boy said "I was talking to Will [his son] and he said he was talking [online] to someone and he said,well, I didnt know he was a boy when I first met him. and I said, 'well, you learn these things.' And I would think that over the Internet where you can be anybody or be anything that there is a danger there, if youve got a good line of talk, you can lead people in a long way and they dont know what you are because its sort of like, the goos side and the bad side...." Another father of a ten-year old said "...my concern too is that fictional world aspect because kids already have a hard enough time differentiating between whats real or not, in television and film and now even on the Internet. Even my oldest, whos ten, still, if he sees it, its real, and if sees it in print, its real, and if he sees pictures its real, and still has a hard time differentiating or evaluating things because he doesnt have anything to evaluate against yet...."
It seems apparent that these parents value their childrens facility with computers and Internet resources, and that they try to discuss certain privacy and protection issues with their children. At least four parents mentioned that they had set up guidelines about not giving out names and addresses, and others implied the same. However, there is a current of worry around the subject of their childrens Internet use. The need for clear guidelines, warnings and instructions on sites would help to ease some of their concerns.
The parent of a 14-year old boy and an eight year old girl commented "I think what would help a lot is having - I dont know, maybe these are out there and Ive been oblivious to it or it just kind of caught me off guard - but just having guidelines like, you know, a booklet or pamphlet, to sit down and talk to your kids about these things, because Im fairly computer literate and I work with computers all day and I know a lot about kids software but you just dont think. You think youre giving your kids this great advantage, this computer and Internet, cause they can do homework, they can do research, and then all of a sudden the dark side creeps up on you."
The most pertinent policy question seems to be: what might we need to protect children from, and at what ages do children need such protection? Given the high deception potential of places such as chat rooms as well as the silent data-gathering that occurs as one explores the Web (see below). There may be some grounds for considering protections that are built into systems rather than volitional: if we cannot depend on children to exercise good judgment, then the sites they logically spend most of their time with should offer it unconditionally.
Session Three: Do schools, libraries and other settings in which children may have access to the Web have a role to play in protecting childrens privacy?
Response: The prevailing sentiment in our focus groups was that schools and libraries primarily are interested in limiting their liability for any potential damage to children that could occur as a result of their Internet access capabilities. Using filtering software such as Net Nanny or CyberPatrol is one common institutional response, particularly among libraries. The Austin city library had installed CyberPatrol earlier this year and put its filtering mechanism on the highest level; one parent commented that he was using a library computer to search for a friends email address and the name was blocked with this filtering software because his friends first name was "Luther." Another commented that "theres a whole list of places you can go to basically get around blocking, so that stuffs out there." This dissatisfaction with the filtering software was linked to a general sense that filtering was not going to be a realistic answer to limiting childrens access to certain material if those children were sufficiently motivated to get to it.
Using the Internet in schools is increasingly common, although schools and states differ widely in how much access they offer children. It appears to be common in public schools to develop Internet projects that cultivate "e-pals," the electronic version of penpals. This enables children to practice writing while also allowing them to learn about other cultures. However, for one of our group members some uninvited and untoward correspondence occurred in these assignments: an older teenager (15 years old) from Norway sent some language to a local elementary that was objectionable. The consequence of this was that the school entirely abandoned its use of the Internet for a while. Some group members assumed that schools would probably have somebody monitoring their childrens Web use, and that either a teacher or the public nature of the computer monitors in that setting would take care of privacy concerns.
The overwhelming perception is that filtering software is ineffective and doesnt deal with the larger problems of (1) linking children with appropriate content, (2) teaching children to behave civilly, and (3) providing them with the skills to evaluate truth and falsify as well as to assess danger and opportunity. While schools may have a role in insuring childrens access only to "approved" sites, commercial or noncommercial, parents did not see school policies as any final answer to the issue of childrens privacy or protection.
Appendix I: Content Database Codebook
Appendix II: Focus Group Protocol
Children and Internet
Focus Group Questions
1. What sort of access to the Internet do your children have at home? How closely are you involved with your childrens use of the Internet?
2. What do your kids do on the Internet?
3. Have you had any firsthand experience with material you think is inappropriate for children, or problematic? Explain.
Have you encountered any situations that caused you concern with your childs use of the Internet? What were they? Reactions?
4. What sorts of conversations, if any, have you had with your children about what to do on the Internet? Do you have any rules or restrictions? Any other computer use rules in your household?
5. What concerns you most regarding children and net use? privacy? inappropriate content? commercialism? physical threats/harm? something else?
6. Do you use or have you considered using any filtering software or other technological means of restricting access? What are your thoughts about this? (CyberPatrol, Net Nanny, etc.)
7. Do your children have Internet access outside of your home? What sorts of concerns do you have about such access? How do you feel about the public librarys use of CyberPatrol on its computers?
8. Have you sought Internet material or sites specifically geared to children? What are your thoughts about them?
9. Are you aware of Internet sites with advertising on them? Reactions?