|March 19, 1998
Office of the Secretary
Re: Privacy Guidelines 1998 -- P954807
To the Secretary:
On April 21, 1997, the Children's Advertising Review Unit (CARU) of the Council of Better Business Bureaus issued a newly revised edition of its Self-Regulatory Guidelines for Children's Advertising, including a new section addressing concerns unique to the interactive electronic media. One section specifically addresses the critical issues of data collection from children.
The Guidelines call for advertisers to use "reasonable efforts to insure that parental permission is obtained" when collecting information from children.
In June 1997, following the Commission's Public Workshop on Consumer Privacy, CARU released a further definition of "reasonable efforts", depending on the type and sensitivity of the information collected.
Attached for the record are the Guidelines for Interactive Electronic Media and the current definition of CARU's Reasonable Efforts standard. The full text of the Self-Regulatory Guidelines for Children's Advertising are part of the record of the 1997 Workshop, and can also be found at < www.bbb.org/advertising/caruguid.html >.