Comments of Michael Brody Concerning Consumer On-Line Privacy-P954807
MICHAEL BRODY M.D., P.C.
April 15, 1997
Re: Public Workshop on Consumer Information Privacy/Request to Participate, P954807
As a child psychiatrist and a member of the American Academy of Child and Adolescent Psychiatry's Media Committee, I would like to participate in FTC's Public Workshop on Consumer Information Privacy. Specifically, I would like to address the questions raised as part of the discussion to take place in Session Three: Children's Online Privacy.
I am deeply disturbed by the ways marketers and advertisers are collecting personal information from children using the Internet. In particular, I am concerned that companies are taking advantage of children's vulnerabilities, capitalizing on children's inability to understand sophisticated marketing promotions.
Michael Brody, M.D., P.C.
Jean Piaget demonstrated that children progress cognitively in stages from illogical thought to concrete concepts--the ability to make groupings and categories--to formal operations--the ability to manipulate these classes and groups. There are stages in the development of thinking as well. Only when a child reaches formal operations, which occurs around ages 13 to 15, can she or he use hypothetical-deductive reasoning. This is reasoning based on thought and logic, which allows the child to mentally test alternatives, and understand the fallibility of authority, including a character spokesperson, and realize the seductiveness of advertising.
Until children have that intellectual judgment, which evolves slowly, they do not have the ability to consent. Instead, this is our job as a parent. We must know how much control/consent to give up to our kids. One question that must be asked is this: Do we measure children's ability to assume consent by age or behavior? We certainly have to factor in risks--physical and mental--for the type of consent allowed. This is why our children can not drive cars in most states till they are 16, or drink until 21. As a society we have determined these ages of consent. It is harmful to give young children the right of consent to engage in financial interactions with exploitative strangers. It promotes an unfair advantage that pressures not only the youngster but her parents. It is harmful to a child and her family to be seduced into buying or giving information to please a cartoon character to whom the child is loyal from another context--TV, movies or video.
When the Web sites use the information collected from the child to microtarget a child with unsolicited E-mail, such as a valentine from one of the Power Rangers (plus some commercial message), the seduction and exploitation is even more intense. These customized advertisements are too intrusive and the information used to plug into a child's psyche received surreptitiously. At some point the child is bound even closer to these characters who have now become super salesmen, occupying even more of the child's fantasy life.
Cyberspace is in its infancy. Soon, like television, it will be a part of all children's lives. And like television, more time online means less time to read and play, which are necessary to promote imagination and socialization. Unfortunately, the Web sites that have been launched are variations and spin-offs of children's TV programming: the same chases, the same rescues, superheroes, jagged narratives and stereotyping with the same goal to sell more and more products. Cyberspace, like video tapes and TV, self refer back to a commercial product: a movie, toy, or doll.
And yet cyberspace is so much more immediate than TV, and with microtargeting so much more personal. It is a superb marketing tool that needs parameters in dealing with our already over media-blitzed young children.