Agency Information Collection Activities; Proposed Collection; Comment Request; Admongo Evaluation #00002

Submission Number:
00002
Commenter:
Shaina Kalanges
State:
Illinois
Initiative Name:
Agency Information Collection Activities; Proposed Collection; Comment Request; Admongo Evaluation
Matter Number:

P085200

Admongo Evaluation, FTC File No. P085200 1.Whether the proposed collection of information is necessary for the proper performance of the functions of the agency, including whether the information will have practical utility: The notice flags the three agency functions of: (1) Raising awareness of advertising and marketing messages; (2) teaching critical thinking skills that will help children analyze and interpret advertisements; and (3) demonstrating the benefits of being an informed consumer. The Federal Trade Commission (FTC) elaborated even further on modern concerns of big data collection and analysis related to advertising and marketing in the 2013 Reclaim Your Name 23rd Computers and Privacy Conference. This conference specifically demonstrated a pressing need for a tool that will educate people in the 8-12 age range about advertising and marketing. The information gathered by this proposed study will have practical utility on how well Admongo actually works to educate children ages 8-12 about modern advertising and marketing techniques. With a better understanding of Admongo’s effectiveness, the FTC can either continue to provide access to the game or make improvements. A game that actually works to educate in these areas will held the FTC accomplish the goal of consumer education on big data collection practices related to advertising and marketing that have harmful effects on young people using the internet. The statistics provided by the control group could show that Admongo is inefficient and does not teach children more than they already know. But, if the study reveals that Admongo is effective, the FTC may promulgate more effective rules and regulations to protect young consumers. However, if Admongo is not accessed enough by the schools it was distributed to, the study may not be necessary. Also, Admongo was only widely distributed to fifth or sixth grade classes according to the notice, which do not encompass an entire 8-12 age range group. At a minimum, if these children will access this game at each recipient school, this may help the studies reflect one half of actual and potential game usage in the future. There is also an issue with the type of children the study will collect data from. This is also addressed in answer 3. The format of the study calls for volunteers to participate at home. While this may be less burdensome, it excludes a large portion of children that may only have access to computers at school at their current age, and may actually be more vulnerable to advertising and marketing messages. 2.The accuracy of the agency’s estimate of the burden of the proposed collection of information, including the validity of the methodology and assumptions used: The calculations appear accurate because the study has set times for each function to be performed by participants. The group that is using Admongo before taking the test cannot possibly be compared to a control group who never uses Admongo to come up with the most accurate result of the program’s efficiency; but, this is likely the best proven method. 3.Ways to enhance the quality, utility, and clarity of the information to be collected: There may be huge disparities in the sample of volunteers that provide the data in this study. Electronic collection of information at home limits the selection of young people to those that actually have the proper equipment at home to perform this study. A large portion of children in the United States will be left out of this study, while the majority of those included will likely be similar in socioeconomic status. Generally, when parents consent to each child that volunteers the parents should also certify that each child will be taking the test without assistance if in the control group, and only with Admongo if otherwise. 4.Ways to minimize the burden of the collection of information. None.