TERRA INCOGNITA
Privacy Horizons

29^th International Conference of
Data Protection and Privacy Commissioners

"The Next Generation" Dragon
Children's Online Privacy

September 27
10h45 – 12h

Terra Incognita, workbook series # 10

Table of contents

Biographies

• Mr. Francesco Pizzetti — Chair
• Dr. Jacquelyn Burkell
• Dr. Leslie Regan Shade
• Dr. Valerie Steeves

Children’s Online Privacy — Policy Concerns

Biographies

Chair

Mr. Francesco Pizzetti
Francesco Pizzetti is President of the Italian data protection authority. He is Full Professor of Constitutional Law at the University of Turin ’s Faculty of Law, Professor at the Link University of Malta in Rome and has held academic offices at other Italian universities. He advised Italian governments on constitutional law and public administrative law (1987-2001), and served as deputy-mayor of Turin (1990- 1993). He has also served the government on several conferences and commissions and was Director of the Italian Superior School of Public Administration from 1998 to 2001. He is a member of the Council of the Presidency of the Italian Administrative Judiciary and a member of the Board of Directors of the Italian Association of Constitutional Law. He has performed extensive research on Italian and European Constitutional Law, concentrating on Italian Constitutional Reform, federalism, and developing a complex system of governance within the European framework and legal order. He has also written several books, papers and articles on constitutional law and administrative reform.

Speakers

Dr. Jacquelyn Burkell
Jacquelyn Burkell is a member in the Faculty of Media and Information Studies at the University of Western Ontario. She holds a PhD in Cognitive Psychology, and her research interests include the social implications of technology. She is currently involved in a SSHRC-INE, along with Val Steeves and many other research partners, that examines the impact of technology on privacy. Ms. Burkell teaches courses on technology in the Media, Information, and Technoculture program that examine new technologies and our interactions with them.

Dr. Leslie Regan Shade
Leslie Regan Shade is an Associate Professor at Concordia University in the Department of Communication Studies. Her research focus since the mid-1990’s has been on the social, policy, and ethical aspects of information and communication technologies (ICTs), with particular concerns towards issues of gender, globalization, and political economy. Her research contributions straddle the line between academic and nonacademic audiences, including policymakers and non-profit groups. Dr. Shade was the Principal Investigator for a Social Science and Humanities Research Council-funded project that looked at domestic use of the internet in the home for children and youth.

Dr. Valerie Steeves
Valerie Steeves is an Assistant Professor in the Department of Criminology and the Faculty of Common Law at the University of Ottawa. Dr. Steeves has written and spoken extensively on privacy from a human rights perspective, and is an active participant in the privacy policy making process in Canada. She has also written a number of reports on children’s use of new media, including Young Canadians in a Wired World (Media Awareness Network, 2005), and is the author of a series of multimedia games designed to teach children how to protect their human rights in a networked environment. Her game Sense and Non Sense won the first annual Award of Excellence in Race Relations Education from the Canadian Race Relations Foundation in 1999, and her game Privacy Playground won the Bronze Medal at the 2006 Summit Creative Awards Competition, an international competition involving thousands of entries from 26 countries. In 2004, she was awarded the LaBelle Lectureship at McMaster University, a juried prize given to scholars doing cutting edge research and challenging accepted ideas.

TERRA INCOGNITA
Privacy Horizons

29^th International Conference of
Data Protection and Privacy Commissioners

Children’s Online Privacy Policy Concerns
by: Valerie Steeves

This paper provides a brief overview of the policy concerns that have been raised concerning children’s online privacy. I start by examining the impetus for enacting the Children’s Online Privacy Protection Act of 1998, and then examine some of the criticisms of the Act (and the data protection regime upon which it is based) that have been raised in the academic literature. I then outline some of the research findings regarding children’s privacy attitudes and behaviours, and the role that privacy plays in children’s development.

I argue that the current legislative framework, which relies on fair information practices to give children (and parents) control over the collection and use of children’s personal information, may be insufficient to protect children’s online privacy for two reasons. First, it fails to take into account the social meaning of children’s online activities. Second, it does not constrain the business imperatives that drive the commercialization of children’s private play spaces. Ironically, these two factors combine to legitimize a further reduction in children’s privacy in order to protect them from invasive practices and offensive content. In order to avoid these pitfalls, policy solutions must recognize that fair information practices are a floor rather than a ceiling, and provide additional mechanisms that limit the commercial exploitation of children’s online spaces and ensure that children’s developmental needs for privacy are respected in online spaces.

Restraining the Web of Deception – The Introduction of the Children’s Online Privacy Protection Act of 1998

Children’s online privacy was first raised as a policy issue in 1996, when the U.S.-based Center for Media Education (CME) released its report, Web of Deception: Threats to Children from Online Marketing (Montgomery, 1996). The report documented a number of marketing practices embedded in web sites designed for children, including the seamless blending of advertising with content, and the aggressive collection of children’s personal information for commercial purposes. The information collected was used to micro-target individual children with advertising, and to develop detailed profiles of children as consumers. Collection was also masked as "play" – kids were encouraged to provide personal information in order to join a club or enter a contest – and the fact that the playground was created as a tool for market research was invisible to the users.

The CME argued that these constituted deceptive trade practices and called for a ban on:

1. Collecting children’s personal information (including clickstream data);
2. Hypertext links between content pages and advertising pages;
3. Any interactivity in which children "talk" to product spokes-characters;
4. Online micro-targeting or direct-response marketing involving children.

Concerned that young children cannot differentiate advertising from other content, the CME also called upon marketers to clearly label any advertising as such.

The U.S. Congress was quick to respond and, after a series of Congressional hearings, it passed the Children’s Online Privacy Protection Act of 1998 (COPPA). COPPA provides that sites "directed to children" must seek verifiable parental consent for collection of information from children under the age of 13. In order to be "verifiable", the site operator must take reasonable steps to ensure that the parent receives notice of—and consents to—the site’s information practices. The primary method of doing this is through a Privacy Notice posted on the site. The Notice must stipulate what information is collected and for what purposes, whether the information will be disclosed to third parties, how the information is secured, and how to contact the site operator for access to the information or to request the information be deleted. Children 13 and over are deemed to be competent to consent on their own behalf.

The procedural protections contained in COPPA were modelled on the general data protection regimes in place elsewhere, and accordingly children’s personal information enjoys some level of protection in the more than 40 jurisdictions that have passed privacy laws to date. However, it is interesting that early in the U.S. legislative process, the broader concerns raised by the CME about the commercialization of children’s online play receded as reform efforts focused on the narrower questions of access, security and consent.

The protections offered by COPPA have been criticized for a number of reasons. Site operators are only required to comply with the Act if they have actual knowledge that a user is under 13, and many rely on a blank statement that the site is not intended for use by children to avoid responsibility (Hertzel, 2000, p. 443). This is particularly problematic given the evidence that children prefer to frequent sites that are designed for adults (Burkell & Steeves, forthcoming). Many of the processes in place to verify parental consent by fax, toll free telephone lines or email are inconvenient and unwieldy (Grimes & Shade, 2005, p. 191), and policing non-compliance is difficult as it is hard to detect violations (Hertzel, 2000, p. 443). In addition, some children tell us that they simply lie about their age or provide a false parental email address in order to gain access to a site (Media Awareness Network, 2004).

Privacy policies on the sites kids visit are also open to criticism. Almost all of them are hard to find, long, and written at a reading level that makes them difficult for children – and many adults – to understand (Burkell & Steeves, forthcoming). Children report that they are unlikely to read policies because they are long and boring (Media Awareness Network, 2001, 2004), and when they do read them, they complain that the legal language and the complex structure are intended to take advantage of them because they do not read at a university level (Burkell, Steeves & Micheti, 2007, p. 24). But perhaps most troubling is that data protection legislation like COPPA has done little to curtail the burgeoning trade in children’s information. Detailed dossiers on a million pre-schoolers, with names and addresses, for example, can be purchased for as little as $5.00 (U.S.) (Electronic Privacy Information Center, 2003).

Child as Commodity

One of the most compelling criticisms of the current regime is that its focus on personal information neglects the fact that aggregate statistics can be used to invade online privacy. Aggregate profiles, created by pooling massive amounts of personal information, are used to subdivide online users, including children, into clearly defined audiences so access to them as individuals can be sold to advertisers (Estrin, 2007, p. 2).

This kind of micro-marketing does more than just deliver advertising. Sites aggressively collect information from children both directly and by recording their movements, interactions and discussions with others, then use that information to develop an intimate relationship between the child and the marketer (Chung & Grimes, 2005, p. 527). Marketers play upon children’s developmental needs to experiment with roles, communicate with peers, take risks, and seek advice on issues that are important to them, in order to encourage children to reveal information about themselves (Steeves, 2006; Youn, 2005). They then use that information to create a relationship between the child and the brand, and to manipulate the child’s sense of identity to make him or her more amenable to purchasing messages (Steeves, 2006, Linn, 2004).

To fully protect children’s privacy in the online environment, we must acknowledge the ways in which aggregate information can be used to manipulate individual behaviour (Shade, Porter & Sanchez, 2005; Grimes & Shade, 2005; U.S. Public Interest Research Group & Center for Digital Democracy, 2007). The crux of the issue is that the marketing system rests on surveillance. As marketing guru Rob Graham puts it, "There's no way to sugar coat this. In order to learn more about individual consumers, marketers have to resort to 'spying’" (Graham, 2006, cited in Estrin, 2007, p. 4). Information that is collected about individual children in this way may or may not be associated with the child’s name; however, it is funnelled into a system that categorizes unique individuals according to patterns of behaviour they share with others. Based on that categorization, the individual child is not just targeted with advertising when he or she returns to the site, but is "retargeted" – in other words, the marketer feeds the child information in order to change his or her behaviour. As one marketing expert puts it:

The beauty of [behavioural targeting] is that it allows publishers and advertisers to learn more about their customers not as group, but as individuals. Rather, than sifting through mountains of data meant to encapsulate the buying patterns of groups of people, [behaviour targeting is] a way to look into the minds of a single, potential customer (Estrin, 2007, p. 1).

In this system, the child becomes the commodity that is sold to advertisers: "Instead of selling a media product itself, [an online playground] is selling information about the children and young adults who are its fans" (Seiter, 2004, p. 98).

A growing number of commentators are questioning whether or not the current privacy regime, with its emphasis on transparency and consent, is capable of protecting children in this environment (Livingstone, 2003). Research indicates that it is difficult for young children in particular to understand questions about privacy and the consequences of disclosure (Shade, Porter & Sanchez, 2004). Children are also much more likely to reveal personal information in exchange for a gift or benefit, without fully recognizing the reasons why the information is sought (Turow, 2001; Cai & Gantz, 2000). Moreover, they are often not given any real choice; children who do not wish to register or provide personal information for access to services like Hotmail or Instant Messaging are told simply not to use the service (Steeves, 2006).  Many children report that, in those circumstances, they just press ‘click’ and accept whatever terms of service are imposed on them, whether they like it or not (Burkell, Steeves & Micheti, 2007).

To ensure we fully protect children’s privacy, it is essential that policy makers take into account the commercial imperatives that drive information collection. As Chung and Grimes warn:

While it may be more difficult to imagine knowledge of children’s play habits and social interactions as a highly valuable commodity, the reality of the $115-billion children’s consumer market and the massive revenues collected by children’s marketers research play in the relationship that exists between children playing online and the continued growth of children’s commercialized entertainment is crucial to understanding the consequences of the processes that unfold within the children’s digital playground (Chung & Grimes, 2005, p. 541-542).

Child as Victim

One of the reasons that it has been difficult to restrict the commodification of children’s online privacy is that policy makers often see the problem as a safety issue (Hertzel, 2000). From this perspective, the interactive nature of the Internet puts kids at increased risk of being watched by pedophiles and other ill-intentioned "strangers". Qualitative research with children indicates that the stranger-danger message has been communicated effectively (Livingstone & Bober, 2003, 2004; Media Awareness Network, 2004). As one child in Toronto put it, the rules are clear: "No porn, no chat, no personal information" (Media Awareness Network, 2004).

Ironically, the desire to protect children from "strangers" has had the paradoxical effect of placing children under increased online surveillance. Commercial sites have tended to equate privacy risks with safety, teaching kids to guard their personal information from "strangers." However, kids are encouraged to reveal information to marketers and corporations. For example, Neopets.com, the premier children’s marketing research site on the Web¹, warns kids not to give out personal information to other children on the site or to "strangers" on the Net. The site also encourages kids to report any suspicious activity so Neopets can "take any necessary action" to protect them². In this sense, the corporation purports to be part of the solution, rather than part of the problem, and commercial surveillance is normalized.

For their part, parents are encouraged to use key capture software and other technical "fixes" so they can see exactly what their children are doing online, in order to "keep them safe"³. Some commentators warn that these kinds of approaches tend to breed fear and suspicion, and make it more difficult for children to maintain relationships of trust with their parents and other adults (Livingstone, 2006). They may also be counterproductive. Kerr and Stattin (2000) report that increased parental monitoring of children does not correlate with a decrease in anti-social behaviour as previously reported; rather, children who spontaneously disclose information about their lives to their parents in the context of a relationship built on mutual trust are less likely to act in an antisocial manner.

The argument that we need to place children under surveillance to keep them safe also feeds into a "moral panic" about the dangers of the Internet (Lawson & Comber, 2000). The more fearful adults become, the harder it is to provide children with opportunities to enjoy privacy, which is essential to developing a healthy sense of autonomy (Tang & Dong, 2006). Schools are a case in point. Although the Internet is recognized as an outstanding curricular resource, many schools place students under virtual surveillance and threaten them with a loss of computer privileges if they violate the school’s acceptable use policy (Lawson & Comber, 2000). The intent is to protect children from invasive behaviour on the part of others and to restrict their access to questionable content. However, this type of surveillance may backfire. Davis notes:

To discern and to ‘own’ appropriate connections and justifications requires a certain kind of ‘privacy’ from the teacher. That is, the teacher, as authoritative source of knowledge, needs to be distanced in some measure from the processes through which this discernment and ownership is acquired. In some measure the teacher must lack detailed access to the child’s thinking processes, at least for some of the time, and the child must be aware that the teacher lacks this access (emphasis in original, Davis, 2001, pp. 252).

Blanket surveillance may then work against the best interests of children as it interferes with the learning process itself.

Child as Suspect

The use of online surveillance in schools as "some sort of scare tactic about being caught out" (Lawson & Comber, 2000, p. 281-282) may also impede the development of democratic sensibilities (Davis, 2001). A number of Canadian students who participated in focus groups in 2004 reported that they were afraid of pornographic pop-ups that appeared spontaneously on school computers—not because they did not know how to deal with the content, but because they would not be able to prove to teachers that they were "innocent" (MNet, 2004).

Giroux argues that children are "increasingly isolated, treated with suspicion, and subjected to diminished rights to privacy and personal liberties" (Giroux, 2003, p. 553), particularly in schools. He warns that zero tolerance policies (and acceptable use policies by extension) run the risk of criminalizing young people’s behaviour and creating a "generation of suspects" (p. 554). Garrett
(2004) has similar concerns about the increasing use of databases to monitor "troublesome" youth.

A number of commentators contend that children are now subjected to more surveillance than ever before (James & James, 2001), and that the use of monitoring has become "central characteristic of modern childhood" (Fotel, Thomsen, 2004, p. 535). In these circumstances, it is even more important to develop policies that protect children’s privacy in the fullest sense.

Why Children’s Privacy is Important

Understanding children’s privacy attitudes and behaviours is an important piece of the policy puzzle, and yet policymakers to date have tended to ignore the impact of data protection policies on kids’ experiences (Shade, Porter, Sanchez, 2005, p. 521). Early polls that indicated that children are willing to trade away personal information in order to win a prize or enter a contest (Turow, 2001; Media Awareness Network, 2000) led many to conclude that young people do not care about privacy. However, there is a growing body of research that indicates that children actively seek online privacy—but they seek it from their parents, their siblings, and their teachers (Livingstone, 2006; Livingstone & Bober, 2003, 2004; Media Awareness Network, 2004).

Children value their online privacy precisely because it gives them a safe space in which to try on new identities, experiment with social roles, communicate with peers, and get a glimpse of an adult world that is otherwise closed to them (Livingstone, 2006; Steeves, 2006). They move seamlessly between real world activities and online communication, often talking on the phone, doing homework online, chatting with friends on Instant Messaging and downloading music, all at the same time (Media Awareness Network, 2000).  Rather than isolating them, the Net gives them a way to extend their real world social networks. Younger children often prefer online communication to face-to-face conversations or telephone calls because it is harder for others to overhear them. It also gives them a way to manage any potentially embarrassing situations as they can pretend they were kidding or otherwise "elegantly withdraw from the stage" in the Goffmanian sense (Livingstone & Bober, 2003, 2004).

Children also micro-manage their online privacy and actively resist parents’ and teachers’ surveillance (Livingstone & Bober, 2003, 2004; Hope, 2005). They liken adult cyber-snooping to having their pockets picked (Livingstone & Bober, 2003, 2004) or being stalked (Burkell, Steeves & Micheti, 2007). This is ironic, given that well-meaning adults often resort to these types of practices in order to protect their children’s privacy from strangers.

On the other hand, children are often naive about corporate surveillance (Shade, Porter, & Sanchez, 2005), and can appear to passively accept it as a fact of life (Burkell, Steeves & Micheti, 2007). Nonetheless, there is evidence that they are uncomfortable with the ways in which they are constantly monitored by online corporations. Although they routinely "click through" in order to get access to online games or communication platforms, many lament their lack of options. As a 15-year old Canadian girl puts it, "Like, if we had a choice to say no, I would choose no. We can’t or else we can’t go on the thing for some of them" (p. 14). Interestingly, this lack of options translates into a general distrust of the corporations that house the sites they visit. In the words of a 17-year old Canadian boy, "Well, they’re taking advantage of you, that your friends have a Hotmail account, they’re on Messenger, like you have to have Messenger... It’s another way to control you" (ibid).

Although data protection laws offer some protection, policy makers have yet to fully accommodate the privacy needs of children. Privacy is an essential element of growing up. Online self-expression is linked to identity formation and a sense of self respect (Stern, 2004), and private online spaces give children an opportunity to develop a sense of autonomy (Livingstone, 2007). Children turn to the Net to fulfill age-appropriate developmental needs for individuation (Tang), and respecting their developmental need for privacy will encourage them to go beyond the acquisition of "thin" procedural skills and develop a facility for deeper, "connected thinking" (Davis, 2001, p. 252).

Clearly, to deny the existence of online risks to children’s safety would be irresponsible (Livingstone, 2006). But at the same time, policy makers must address the ways in which children’s online spaces are structured by pervasive surveillance. Current rules do little to restrict the commodification of children’s private lives, and the ways in which children’s privacy and freedom of expression is limited by organizations that turn them into objects of surveillance.

In order to find a better balance, fair information practices should be supplemented with regulations that limit behavioural targeting of children and immersive advertising in online playgrounds. Schools and libraries should be encouraged to provide children with privacy education, and restrictions on children’s freedom of speech and access to information should be carefully fine-tuned to ensure children benefit from the democratic potential of online communication. Parents also need education and support to better guide their children’s online activities.

Data protection commissioners have a special role to play in this process. As privacy experts, they can support an informed public debate about children’s privacy. They can also provide valuable privacy expertise to governments and administrators who are responsible for managing various aspects of children’s online communications. Data protection principles are an important part of that expertise, but commissioners can also seek to engage governments in a meaningful debate about the value of privacy to children’s development and education. Most importantly, commissioners can reinvigorate the role of privacy as a human right, and seek to advance privacy as an essential element of human dignity and democratic freedom.

Works Cited

Burkell, Jacquelyn, Valerie Steeves and Anca Micheti. (2007). Broken Doors: Strategies for Drafting Privacy Policies Kids Can Understand. Ottawa: Privacy Commissioner of Canada.

Burkell, Jacquelyn and Valerie Steeves. (Forthcoming.) Reading the Fine Print: Assessing the Accessibility of Privacy Policies on Kids’ Favorite Web Sites.

Cai, Xiaomei & Walter Gantz. (2000). Online Privacy Issues Associated with Web Sites for Children. Journal of Broadcasting & Electronic Media 44(2): 197-214.

Children’s Online Privacy Protection Act of 1998, 15 U.S.C. §§ 6501-6506.

Chung, Grace and Sara M. Grimes. (2005). Data Mining the Kids: Surveillance and Market Research Strategies in Children’s Online Games. Canadian Journal of Communication 30(4): 527-548.

Davis, Andrew. (2001). Do Children Have Privacy Rights in the Classroom? Studies in Philosophy and Education 20: 245-254.

Electronic Privacy Information Center. (2003). The Children's Online Privacy Protection Act (COPPA). http://www.epic.org/privacy/kids/

Estrin, Michael. (2007, April 20). Behavioural Marketing – Getting Ads to the Right Eyeballs.
iMediaConnection.http://www.imediaconnection.com/content/14559.asp

Fotel, Trine and Thyra Uth Thomsen. (2004). The Surveillance of Children’s Mobility. Surveillance & Society 1(4): 535-554.

Garrett, Paul Michael. (2004). The Electronic Eye: Emerging Surveillant Practices in Social Work with Children and Families. European Journal of Social Work 7(1): 57-71.

GetNetWise. (1999-2003). Loss of Privacy. http://kids.getnetwise.org/safetyguide/danger/privacy

Giroux, Henry A. (2003). Racial Injustice and Disposable Youth in the Age of Zero Tolerance. Qualitative Studies in Education 16(4): 553-565.

Graham, Rob. (2006). Fishing from a Barrel – Using Behavioral Targeting to Reach the Right People with the Right Ads at the Right Time.  Boscawen, NH: Learningcraft Press.

Grimes, Sara and Leslie Regan Shade. (2005). Neopian Economics of Play: Children’s Cyberpets and Online Communities as Immersive Advertising in Neopets.com. International Journal of Media and Cultural Politics 1(2): 181- 198.

Hertzel, Dorothy. (2000). Don’t Talk to Strangers: An Analysis of Government and Industry Efforts to Protect a Child’s Privacy Online. Federal Communications Law Journal 52(2): 429- 451.

Hope, Andrew. (2005). Panopticism, Play and the Resistance of Surveillance: Case Studies of the Observation of Student Internet Use in UK Schools. British Journal of Sociology of Education 26(3): 359-373.

James, A. L. & James, A. (2001). Tightening the Net: Children, Community and Control. British Journal of Sociology 52(2): 211–228.

Kerr, Margaret and Håkan Stattin. (2000). What Parents Know, How They Know It, and Several Forms of Adolescent Adjustment: Further Support for a Reinterpretation of Monitoring. Developmental Psychology 36(3): 366-380.

Lawson, Tony and Chris Comber. (2000). Censorship, the Internet and Schools: a New Moral Panic? The Curriculum Journal 11(2): 273-285.

Linn, S. (2004). Consuming Kids: The Hostile Takeover of Childhood. New York: The New Press.

Livingstone, Sonia. (2006). Children’s Privacy Online: Experimenting with Boundaries Within and Beyond the Family. Computers, Phones, and the Internet: Domesticating Information Technology. Eds. Kraut, R. E., M. Brynin and S. Kiesler. New York: Oxford University Press. (2003). Children’s Use of the Internet: Reflections on the Emerging Research Agenda. New Media & Society 5(2): 147-166.

Livingstone, Sonia & Magdalena Bober. (2003). UK Children Go Online: Listening to Young People’s Experiences. London: Economic and Social Research Council. (2004). UK Children Go Online: Surveying the Experiences of Young People and their Parents. London: Economic and Social Research Council.

Media Awareness Network. (2004). Young Canadians in a Wired World: Phase II Focus Groups. Ottawa. (2000). Parents and Youth Focus Groups, 2000. Ottawa.

Montgomery, Kathryn. (1996). Web of Deception: Threats to Children from Online Marketing. Washington: Center for Media Education.

Neopets. Safety Tips at http://www.neopets.com/safetytips.phtml.

Neopets. Privacy Policy at http://www.neopets.com/privacy.phtml

Seiter, Ellen. (2004). The Internet Playground. Toys, Games, and Media. Eds. Jeffrey Goldstein, David Buckingham, and Gilles Brougére. Mahwah, NJ: Lawrence Erlbaum Associates.

Shade, Leslie Regan, Nikki Porter and Wendy Sanchez. (2005). "You Can See Anything on the Internet, You Can Do Anything on the Internet!": Young Canadians Talk About the Internet. Canadian Journal of Communication 30(4): 503-526.

Steeves, Valerie. (2006). It’s Not Child’s Play: The Online Invasion of Children’s Privacy. University of Ottawa Law and Technology Journal 3 (1): 169-188.

Stern, Susannah R. (2004). Expressions of Identity Online: Prominent Features and Gender
Differences in Adolescents’ World Wide Web Home Pages. Journal of Broadcasting & Electronic Media 48(2): 218-243.

Tang, Shengming and Xiaoping Dong. (2006). Parents’ and Children’s Perceptions of Privacy Rights in China. A Cohort Comparison. Journal of Family Issues 27(3): 285-300.

Turow, J. (2001). Privacy Policies on Children’s Websites: Do They Play by the Rules? Philadelphia: Annenberg Public Policy Centre of the University of Pennsylvania.

US Public Interest Research Group and Center for Digital Democracy. (2006, November 1). Complaint and Request for Inquiry and Injunctive Relief Concerning Unfair and Deceptive Online Marketing Practices. Filed with the Federal Trade Commission.

Youn, Seounmi. (2005). Teenagers’ Perceptions of Online Privacy and Coping Behaviors: A Risk-Benefit Appraisal Approach. Journal of Broadcasting & Electronic Media 49 (1): 86-110.

Endnotes

1. Neopets is available in 11 languages, including English, Spanish, German, French, Italian, Chinese Traditional, Chinese Simplified, Japanese, Korean, Dutch, and Portuguese.
2. Neopets Safety Tips at http://www.neopets.com/safetytips.phtml. See also, Neopets Privacy Policy at http://www.neopets.com/privacy.phtml. Neopets is COPPA compliant.
3. See GetNetWise’s Loss of Privacy page, for example, at http://kids.getnetwise.org/safetyguide/danger/privacy