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The Privacy Advisor | ‘Risky Business’ study explores ‘vulnerabilities’ of teen privacy space Related reading: BBB National Programs adds Privacy Initiatives senior leadership



Eighty-three percent of U.S. teens, between the ages of 13 and 17, download a mobile application at least once a month.

Of apps marketed to teens, 83% use advertising to earn revenue, compared to 51% of apps directed to general audiences. Teen-targeted apps also include third-party trackers and ask for more user permissions, with an average of 12.9 requests, six to 10 of which are categorized as “dangerous.”

BBB National Programs Privacy Initiatives Senior Vice President Dona Fraser called these statistics, reported in a white paper published by the organization’s self-regulatory TeenAge Privacy Program, “staggering.” “Risky Business: The Current State of Teen Privacy in the Android App Marketplace” analyzes privacy risks in the teen mobile app landscape and assesses how teen data is harvested by the products they use. A total of 53,000 apps available in the Google Play Store were reviewed, narrowed down to 1,156 teen-directed apps that have been installed 20 million or more times.

“It’s clear that advertisers are paying attention to this market. It’s clear that those of us in the privacy space need to be paying attention to this marketplace and understanding what the vulnerabilities are and to address them,” Fraser said. “The white paper is intended to show a bit of a microcosm in regard to the types of risks and vulnerabilities that exist out there in the teen space and our desire to get industry around the table to have some really modest conversations about what’s happening, what can be done, how we can do better, how we can create transparency.”

As an age group that is driven to engage on digital media platforms, teens face privacy risks that are unique from other age groups, the “Risky Business” white paper argues. They are vulnerable to data collected from apps being used to create user profiles, including “what they look like, what they sound like, where they go, who their friends and family are, where they work and live, their daily habits and interests, and even the contents of their phone.” It further points out that while the privacy interests of those under 13 are often discussed and protected through the U.S. Children’s Online Privacy Protection Act, the privacy challenges facing teens are rarely part of the conversation.

“Teens are so much more heavily advertised to than those under 13. There’s buying power that you have in the teen space that you don’t have with those under 13. Their ability to engage in apps is much higher, so they are going to download, do all these sorts of add-ons to enhance their experience, and in doing so, they are likely engaging with ads that are collecting tons of data, sharing data with other entities, and it’s not clear to the user what’s happening,” Fraser said. “That’s a huge vulnerability, and the industry is obviously trying to monetize the teen user. How do we create some transparency there?”

While some lawmakers have proposed raising the protected age range under COPPA to include teens and legislative proposals brought forward over the past year would apply concepts of COPPA to children under age 16 or 17, the white paper calls for a “nuanced approach to setting new standards.”

Fraser said the goal is to continue the analysis of the teen mobile app space while engaging legislators and companies in creating a set of core principles that take into account teens’ habits, preferences and development with a pledge companies can commit to.

“We would prefer to have the opportunity to really engage industry in building out something that not only preempts legislation, but I think engages legislators. Let’s have a conversation: What do you want, what do you think this should look like? And let us build that into the core principles,” Fraser said. “This is not a standalone conversation. I think we need everybody that’s part of this ecosystem at the table to really create a robust set of core principles.”

Some, like Common Sense Media Multistate Policy Director Joe Jerome, CIPP/US, are skeptical of self-regulation. Jerome said Common Sense Media has been supportive of expanding and strengthening COPPA to encompass the teenage group, acknowledging the “Risky Business” study is helpful to raise awareness around the topic of teen privacy risks and protections.

“Until I think all parties acknowledge that there is an actual problem and that problem has to be, frankly, stopped, we’re just sort of looking at reams and reams of data,” he said. “I think from our position, the status quo is the problem and legislation needs to somehow change the status quo. So, I think, at the end of the day, there’s no way to address the problem of the (advertising technology) ecosystem and data being tracked about teenagers without regulation of some form.”

BBB National Programs and its TAPP program are “willing to do the hard work to secure this space,” Fraser said. And with the new political landscape in Washington, privacy is expected to be a priority, which she said will “ramp up the conversation for everybody on all sides.”

“It’s a very tenuous space. We’re dealing with buying power. We’re dealing with teens who are moving into adulthood, and it’s a very vulnerable space that I think requires a certain level of care and analysis that we’ve never really given it,” she said. “I think TAPP is a program that’s well-positioned to lead the conversation on how best to manage this space without burdening the advertisers, burdening the content providers, and also, just not giving teens what they are seeking. There’s no reason we can’t give them really robust environments that also include transparency.”

Photo by Tim Mossholder on Unsplash

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