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The Privacy Advisor | FTC event on digital advertising to children looks at brand-influencer relationships Related reading: A view from DC: Privacy gets inclusive



The ever-evolving nature of online advertising often leaves children most vulnerable to their messages, whether knowingly or unknowingly.

However, in the digital advertising world, children today are even more susceptible to ads that obfuscate the differences between commercials and entertainment, brought in part by so-called influencer culture.

As part of receiving public input on the effects online advertising has on children, the U.S. Federal Trade Commission staff held an all-day virtual web conference titled "Protecting Kids from Stealth Advertising in Digital Media” Oct. 19, which featured child privacy advocates and advertising industry insiders. Topics included the psychology of children and adolescents that make them more receptive to blurred advertising, the harms caused by stealth targeted ads and potential solutions.

“Advertising has changed a lot over the last few decades,” FTC Chairwoman Lina Khan said. “It used to be that every kid watching a TV show would see the same commercial, and it wasn’t hard for parents to keep an eye on the ads that their children were seeing. The rise of social media and targeted advertising changed everything. Now every child is an audience of one.”  

“They interact with digital technologies almost intuitively,” she continued. “It also carries serious risk (because) when kids interact with digital media, they’re exposed to an array of marketing practices that blur the line between advertising and entertainment.”

During one panel discussion, Common Sense Privacy Program Senior Director Girard Kelly said more than half of tweens and teens “engaged with television, online videos, mobile games social media every day,” with 13- to 18-year-olds topping out at more than eight hours of screen time per day, according to a survey conducted by his organization.

Kelly said ads are now targeted to kids and teenagers that all but pinpoint their exact emotional state at a specific time with the intention of manipulating their attitudes to purchasing a certain brand or product in a moment when they are particularly vulnerable, such as after a breakup with a partner.

“The timing or frequency is really important,” Kelly said. “If kids and teens are exposed to advertisements all day long, but to be effective blurred ads require engagement at the precise moment. So maybe that’s when the child or maybe other kids’ who profile just like them, are most susceptible to suggestion.”

Fairplay Executive Director Josh Golin said children who gravitate toward products reviewed by online influencers through “para-social relationships” often believe they have some sort of a relationship with an online personality, he said.

As a result, Golin said influencers being required to disclose any paid relationships they have with a specific product or brand would not get to the heart of the problem because children and teens may end up developing positive attitudes toward a certain product even if it was used in up-front branded content. 

“Children are less likely to understand what's going on and to be able to defend themselves against (advertising through parasocial relationships), in fact, even adults are less likely to defend themselves against influencer marketing,” Golin said. “It is completely unrealistic to think that at that moment, kids are going to activate those complex cognitive processes in order to defend themselves against those ads.”

On the panel that explored solutions for better regulating blurred advertising, YouTube Managing Director for Global Policy and Advocacy Josh Blumenfeld said his company conducted three rounds of research to ascertain how much kids, parents and childhood development experts understand how digital marketing works.

At the start, Blumenfeld said only one-in-10 children understood the meaning of “paid promotion.” YouTube Kids does not allow personalized ads, while regular YouTube allows for blurred advertising with disclosure.

In the next round, YouTube incorporated the images, text and iconography children and parents reported as being helpful in getting them to understand advertising more. Blumenfeld said YouTube created a 30-second video in "plain English" to pair with channel creators' content, which informed viewers the channel's creator received compensation from a brand.

“Those three elements are a distinctive visual icon, easy to read texts, and a fully animated educational video,” Blumenfeld said. “We found that once we implemented this, we went back to all of our test subjects. And we found that the majority of kids were able to identify the disclosure ... and they were they were able to identify (the) three really key concepts (of images, text and iconography).”

Going forward, more comprehensive disclosures between content creators and the brands that pay for placement must be made clearer for audiences of all ages, said Encode Justice President and founder Sneha Revanur, who added that it would be a first big step. She said to promote the most understanding among users about creator-brand relationships, she urged for such disclosures to be prominently placed near the content on the webpage and formatted similarly. 

“Disclosures should communicate clearly who is paying for an ad and should generally include any information that could actually affect a consumer's decision to buy a product,” Revanur said. “A disclosure should be visually accessible, and the syntax and language should be easy to understand. Users should be able to see that information plain and clear, they shouldn't have to scroll.”

At the conclusion of the workshop, FTC Associate Director for Advertising Practices Serena Viswanathan said the feedback raised by panelists would be incorporated into potential future rulemaking for restricting blurred advertising to children. However, she did provide a general timeline as to when such rulemaking could begin. The FTC's public comment portal on digital advertising to children is open until Nov. 17. 

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