SECTION II NONPROFIT EFFORTS
Organization
Name
Children's Advertising Review Unit (CARU)
Council of Better Business Bureaus, Inc.
Contact Name Elizabeth Lascoutx, Esq.
Vice President / Director
212-705-0123
Fax 212-308-4743
elascoutx@caru.bbb.org

A. Cassidy Sehgal
Staff Attorney
212-705-0117
Fax 212-308-4743
csehgal@caru.bbb.org

845 Third Avenue
New York, NY 10022

www.caru.org

Program/Project
Description
Self-Regulatory Guidelines for Children's Advertising: A self-regulatory system for child-directed advertising since 1974, the Guidelines were revised in 1996 to address critical issues of data collection from children and privacy concerns. CARU works with Web sites, through our own monitoring and requests for reviews, to ensure compliance with the Guidelines, the key provisions of which are:
  • For real world, personally identifiable information, which would enable the recipient to directly contact the child offline, the company must obtain prior verifiable parental consent regardless of the intended use.
  • When personally identifiable information (such as e-mail addresses or screen names) will be publicly posted, which will enable others to communicate directly with the child online, or when the child will be able otherwise to communicate directly with others, the company must obtain prior verifiable parental consent.
  • When personally identifiable information will be shared or distributed to third parties, except for parties who are agents or affiliates of the company or provide support for the internal operation of the Web site and who agree not to disclose or use the information for any other purpose, the company must obtain prior verifiable parental consent.
  • For online contact information collected to respond directly to a child's specific request, the company must directly notify the parent of the nature and intended uses and permit access to the information sufficient to permit a parent to remove or correct the information.
Key Highlights
Milestones
CARU's Guidelines for Interactive Electronic Media served as the basis for the children's standards adopted by the OPA, Trustee, and BBBOnline, and the FTC recommendations to Congress. The Children's Online Privacy Protection Act of 1998 (COPPA) essentially codifies the CARU Guidelines.
Results Forecast Since 1996, when CARU first instituted its Guidelines for Interactive Electronic Media, we have monitored and worked with more than 150 child-directed sites to secure compliance with our Guidelines. Site operators have made great progress in devising comprehensive privacy protections since the release of CARU's Guidelines. We will continue to encourage site operators to embrace our standards for privacy protection through compliance with our guidelines and by continuing CARU's routine patrolling of children's sites. The voluntary compliance rate that CARU has achieved with Web site operators is roughly equivalent to our success in monitoring traditional media -- in excess of 98 percent. In the online media as in the traditional, in the event of non-compliance, we can and do refer to the appropriate government agency, in this instance the FTC.
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