“It does my head in … buy it, buy it, buy it!” The commercialisation of UK children's web sites

The Authors

Agnes Nairn, EM-Lyon Business School, Ecully, France

Acknowledgements

Received June 2008, Revised August 2008, Accepted August 2008. This paper is based on a research project “Fair game? Assessing commercial activity on children's favourite web sites and online environments” carried out by the author in conjunction with ChildNet International and the National Consumer Council. The project report is available at www.ncc.org.uk/nccpdf/poldocs/NCC182rr_fair_game.pdf

Abstract

Purpose – Against a background of social concern about the commercialisation of childhood, the purpose of the paper is to analyse the commercial activity on the favourite web sites of UK children and report the views of a sample of parents and children.

Design/methodology/approach – The paper reviews the theory underpinning current debate over risks to children from online commercialism and summarises the key provisions laid out in current international regulatory guidelines. The broad principles of protection from harm and deception are identified. This review is used to frame a research design encompassing web site observation and qualitative data collection from children and parents.

Findings – A great deal of advertising is poorly labelled and deceptively integrated into content. Most sites visited by children are created for an adult audience which means 25 percent of adverts were for dating, gambling, loans, surgery and age-restricted products. There was also evidence of pester power, dubious “free” offers and incitement to make impulse purchases using mobile phone credit.

Research limitations/implications – Surveys of commercial activity on children's web sites must be ongoing as technology, advertising techniques and regulation change at a fast pace.

Practical implications – Companies which attract a child audience (inadvertently or not) should revise their strategy for selling advertising space. Advertisers should review potentially deceptive techniques such as advergames, product placements and embedded commercial content. “Wish lists” should be reviewed in the light of guidelines on pester power. Online payment methods available to children should be reviewed.

Originality/value – This is one of the first overall assessments of the commercial content of UK children's web sites.

Article Type:

Research paper

Keyword(s):

Internet; Children (age groups); Advertising; Regulation.

Journal:

Young Consumers

Volume:

Number:

Year:

2008

pp:

239-253

Copyright ©

Emerald Group Publishing Limited

ISSN:

1747-3616

Background

A total of 75 percent of primary school children and almost all secondary school pupils (97 percent ) currently go online in the UK (ChildWise, 2007-2008). In the USA children as young as two are now exposed to internet content either directly or by watching older siblings and parents (Buckleitner, 2008). Most children can no longer imagine a world without instant access to homework information; 24/7chatting with friends; downloads of funny video clips; and pitting their wits against global challengers in massive multiplayer games (see children's comments: Byron, 2008).

From a child's point of view, one of the most attractive features of internet entertainment is that much of it appears to be free: a miniclip game requires no pocket money, a chat on msn does not eat up phone credit; and no cash is involved in having friends round to have a laugh over the latest You Tube clips. However, the on-line content served up to children is, of course, not provided free of any charge but largely offered by profit-motivated organisations. Revenue for the host site is generated in one of three ways: sale of advertising space to third parties; sale to third parties of information gathered from site visitors; and sale of merchandise. Children are strategic targets in each of these business models.

Risks from commercialised children's internet

Most research on children's internet risks has thus far concentrated on children's exposure to sites exhibiting inappropriate content or eliciting undesirable contact. Issues which have received most attention have been the effects of pornography/sexually explicit material (e.g. Mitchell et al., 2003; Peter and Valkenburg, 2006); violence (e.g. Levin and Carlsson-Paige, 2003; Olson et al. 2008; Gentile et al., 2004; Anderson et al. 2007) bullying (e.g. Campbell, 2005; Bullying Online, 2006); grooming (O'Connell, 2003); suicide (Naito, 2007) and eating disorders (News-medical.net, 2006). In contrast to this body of research on content and contact, very little work has been published on the third “C”: commercialism. This is understandable as the extreme outcomes of violence, abduction and child sexual exploitation present a readily understood threat which tap into elemental emotions in a way that the activities surrounding buying and selling simply do not.

However, a growing body of evidence suggests that immersion in a highly commercialised culture can have a range of detrimental effects on children. Children report being treated badly by retailers and being duped and ripped off by unfair trading practice (Mayo, 2005). Other studies point to the conflict within families which arises when parents are unable or unwilling to satisfy children's desires for heavily advertised brands (Sheik and Moleski, 1977; Roberts et al., 2005; Buijzen and Valkenburg, 2003). Most recently researchers have begun to examine links between an attachment to the values of a commercial culture and negative psychological effects such as lower self-esteem, depression and anxiety (Nairn et al., 2007; Schor, 2004; Kasser, 2002; Cohen and Cohen, 1996). Indeed, the UK government has included in its Children's Plan (DCSF, 2007 – see www.dfes.gov.uk/publications/childrensplan/downloads/The_Childrens_Plan.pdf) an assessment of the impact of the commercial world on children's wellbeing (DCSF, 2008 – see www.dfes.gov.uk/consultations/conDetails.cfm?consultationId=1547).

Over the past year or so commercialism has been highlighted across Europe as an internet “risk” for children by the “EUKids Go Online” project (Hasebrink et al., 2007) and the Byron Review (Byron, 2008, p. 89). In the USA researchers such as Kathryn Montgomery (2007) and Warren Buckleitner (2008) have also begun to investigate the nature and extent of the hazards presented by the commercialisation of children's online experience. As a result of the childhood obesity debate, others have examined on line food marketing (e.g. Moore and Rideout, 2007; Mallinckrodt and Mizerski, 2007). However, this research is very much in its infancy and very little has taken place in the UK.

Objective and structure of paper

The objective of this paper is, therefore, to present an overall analysis of commercial activity on the web sites most popular with British children; and to explore the behaviour and views of both children and their parents. As the focus is on the possible downsides of commercialism, the paper begins by examining the ways in which profit-motivated activity on the internet can be said to represent a risk to children. This review is then used to frame a research design encompassing site observation and data collection from children and parents. The findings are presented, conclusions drawn and recommendations for future research and public policy made.

Harm and deception: principles and regulation

International thinking around the effects of commercial activity on children is codified in a range of regulations and guidelines which, broadly speaking, seek to prevent children from two key negative outcomes: harm (physical, mental or moral) and deception. Child specific online regulation exists around the three main revenue-generating areas identified above, namely advertising, sale of information and merchandising of goods and services. These three areas are largely self-regulated by industry bodies with a number of national and international codes evolving to guide responsible practice. This is not a totally coherent or unified process and nor is the treatment of differences in the offline and online environments. The current situation can be summarised as follows. The International Chamber of Commerce (ICC) (see www.iccwbo.org/uploadedFiles/ICC/policy/marketing/Statements/330%20Final%20version%20of%20the%20Consolidated%20Code%20with%20covers.pdf) oversees codes across the world; in the USA the Children's Advertising Review Unit (CARU) (see www.caru.org/guidelines/guidelines.pdf) provides a thorough self-regulatory programme for advertising to children in any medium; and the European Association of Communications Agencies (EACA) (see www.eaca.be/documentation/results.asp?type=6) provides comprehensive ethical guidelines for advertising to children in an effort to ensure that existing codes are understood and implemented in a uniform manner across Europe. Specific UK provisions appear in sections 8.11-8.23 and 19.25-19.34 of the Direct Marketing Association's (see www.dma.org.uk/DocFrame/DocView.asp?id=45&sec=-1) code and in section 47 of the Advertising Standards Authority's (ASA) “CAP Code” (www.cap.org.uk/cap/codes/cap_code/ShowCode.htm?clause_id=1731). These codes are, of course, constantly evolving in response to public debate and technological innovations. The CAP Code, for example, has recently incorporated new rules for food and soft drink advertisements to children from 1 July 2007, and new provisions governing promotion of gambling from 1 September 2007, to conform to the provisions of the new Gambling Act.

While self-regulation remains the norm, an increasing amount of legislation has been passed in this area. By Spring 2008 the EU Unfair Commercial Practices Directive became UK law (as in other member states). This covers misleading advertising and specifically blacklists (bans) hidden advertising such as advertorials; falsely creating the impression of free offers and “including in an advertisement a direct exhortation to children to buy advertised products or persuade their parents or other adults to buy advertised products for them.” In the USA The Children's Online Privacy Protection Act (COPPA, 1999; 112 Stat. 2681) specifically prohibits the online collection, use and disclosure of personal details of children under 13 without parental consent[1].

Legislation is one thing: enforcement, however, is another. The borderless nature of the internet makes enforcement particularly slippery. The COPPA legislation does not apply to sites operating from Europe yet these may be accessed by American children. Likewise sites in the USA will not be subject to the new EU Directive on Unfair Practice. It is also the case that the existing guidelines and legislation do not agree on the definition of a child. While COPPA considers a child to be under 13, the UK Children and Young Person's Act defines a “minor” as under 14 and a “young person” as aged 14-18; the CAP Code considers a child as anyone under 16 and OfCom regard a “child” as under 15 and a “young person” as between 16 and 17. The Information Commissioner – responsible for regulating UK data protection – takes the view that children over 12 are capable of giving their consent to their details being collected by third parties.

Yet, despite the proliferation and ambiguity surrounding the regulation of the commercialisation of children's internet experiences, on examination the key underpinning principles emerge relatively clearly from the various prescriptions: first to protect children from physical, mental or moral harm and secondly, to safeguard them from deception.

Our interpretation of generally agreed practical guidelines which seem to have emerged internationally from these principles is shown below. For the protection of children from physical, mental or moral harm:

Do not show situations which are hazardous or could result in physical, mental or moral harm to children.
Do not show inappropriate sexual or violent material in advertising to children.
Do not advertise products which are illegal for children.
Do not interfere with child-parent relationships by encouraging pester power.
Do not imply that a product will result in greater acceptance by peers by conferring qualities of bravery, loyalty or superiority[2].

The generally agreed guidelines for protecting children from deception are:

Advertising should be distinct from content.
Advertising should be labelled as such.
Links from host site to advertiser's site should be clearly signposted.
Adverts should not imply artificial scarcity or urgency using labels such as “now” or “only”.
Programme characters or celebrities should not signpost links to commercial sites.
Characters should not endorse products where they are part of adjacent entertainment[2].

No one would dispute the responsibility of commercial agents to protect children from inappropriate violent or sexual material for such a responsibility lies with all adults coming into contact with children. The guidelines on pester power and peer pressure are perhaps less obvious. Encouraging children to pester their parents has been viewed as harmful by regulators because of the potential for ensuing family conflict and spin-off negative effects (Sheik and Moleski, 1977; Roberts et al., 2005; Buijzen and Valkenburg, 2003; Schor, 2004). The direct harm to the child can result in two ways. Buijzen and Valkenburg (2003) found that advertising exposure led to increased purchase requests which in turn led to an increased level of disappointment (given that parents cannot fulfil all requests) and finally negatively affected children's life satisfaction (p. 499). Schor (2004), on the other hand, has noted that advertising can drive a wedge between children and their parents:

It's important to recognise the nature of the corporate message: kids and products are aligned together in a really great, fun place, while parents, teachers and other adults inhabit an oppressive, drab and joyless world. The lesson to kids is that it's the product, not your parent who's really on your side (Schor, 2004, p.55).

Nairn et al. (2007, p. 25) found that children who do, indeed, believe their parents to be boring and dull also have lower self-esteem. Reflecting this thinking, the new EU Unfair Practices Directive (EC, 2005) has banned all “direct exhortation to children …, e.g. tell your mum to get it from the local news agency”.

Apart from parents, the other dominant force in children's lives is peers. Pressure to conform to peer norms through owning the right clothes, shoes and accessories is strong (Bachmann et al., 1993; Pilgrim and Lawrence, 2001; Gunter and Furnham, 1998). This can result in brand-bullying, particularly of children without the financial means to purchase the “in” brand (Elliott and Leonard, 2004). The international guidelines for marketing to children thus discourage the use of brands to establish peer social position.

While the regulation to prevent harm focuses on stopping children from being exposed to materials which can cause physical, mental or emotional damage, the guidelines on deception are based on principles of fairness. The American Psychological Association puts it like this:

Because young children lack the cognitive skills and abilities of older children and adults, they do not comprehend commercial messages in the same way as do more mature audiences, and, hence, are uniquely susceptible to advertising influence (Kunkel et al., 2004, p. 1).

Most of the psychological work on the fairness of advertising to children, has, of course, been conducted in the context of TV advertising, but the same principles are applied to the internet. It has been argued for decades that both ability to distinguish advertising from programme content and the skills required to understand persuasive intent are primarily driven by age-related cognitive function. These assumptions rest firmly on the work of developmental psychologist Jean Piaget (1960) who proposed that children's cognitive capacity evolves biologically through a series of pre-determined stages from birth to adulthood. In the social psychology field Selman (1980) has argued that “social perspective taking” and “impression formation” are the two most important aspects in understanding children's social development, which are also important in understanding how children process advertising. Social perspective taking (the ability to see perspectives beyond one's own) is strongly related to purchase influence and negotiation. Impression formation (the construction of social comparisons) is also strongly related to understanding the social aspects of products and consumption.

In the marketing field, Deborah Roedder John's (1999) highly influential review of a 25 year body of literature on the “consumer socialisation of children” has more recently consolidated the ideas of Piaget and writers such as Selman in proposing a three stage process through which children mature, evolve and become socialised into a consumer world: the “perceptual” stage (age 3-7); the “analytical” stage (age 7-11) and the “reflective” stage (age 11-16). In the first stage children understand their universe in terms of what is readily observable and tend to focus on a single dimension at a time. Children of this age have difficulty in thinking about their own perspective and that of another person simultaneously (John, 1999, p. 187). The analytical stage (7-11) is a period of huge change for children's development during which they begin to appreciate more abstract concepts such as value for money and start to develop understanding of advertisers' intentions. Children of this age are also called “cued processors” (Roedder, 1981) as, although they may possess abstract knowledge about, for example, the role of advertising in society, they need cues (such as clearly labelled adverts) in order to be able to retrieve this information. After the age of 11 children's processing capabilities become much more strategic and they begin to understand another person's perspective as it relates to the social group or system to which that other person belongs (Selman, 1980). After entering senior school most children start to appreciate complex notions of a market economy, the social significance of brands and can also start to develop some scepticism towards claims made by advertisers (e.g. appreciate that a celebrity is being paid to endorse a product). However Brucks et al. (1988) have noted that having the ability to be sceptical does not necessarily mean that such abilities will be engaged, a notion backed up more recently by Moses and Baldwin (2005, p. 197) who state that “merely having the concepts in some latent form does little if anything to prevent children from being led astray by advertising”.

So while there is general consensus that below the age of 12 children's cognitive abilities are really not well enough developed for them to make unaided assessments about what is designed to entertain and what is designed to persuade, there is still debate over whether even after this age knowledge about the role of advertising in society is enough to engage a child's critical faculties. And, of course, this evidence is based largely on the context of TV advertising. When we apply these psychological concepts to the fast moving world of internet advertising it becomes apparent that children have even less psychological protection from potentially deceptive practice, for the on-line environment is fundamentally different from TV. Children's exposure to advertising on-line can be prolonged and continuous rather than episodic and confined to the commercial break and it can be interactive, engaging and exciting. The intention behind on-line advertising can also be fundamentally different from that of TV adverts. Viral marketing implicates the child in becoming an active advocate for a product; advergames create a bond with the brand based on emotions of winning and losing; and the time gap between viewing an advert and purchasing the product can be seconds or minutes on-line compared with days or weeks with TV advertising.

The basic economic concepts are rather different too. Children from a very young age understand the principle of the exchange of goods and services for money and know what it means if a toy appears on screen with a price tag attached. However, appreciating that a games site is subsidised by selling advertising space to other companies is a fairly abstract concept which is highly unlikely to be accessible to children under 12. And the machinations of the behavioural targeting industry which deals in data obtained from site registration and cookies requires in-depth industry knowledge as well as an understanding of the marketing value of information. Few children are likely to understand this: indeed, many adults are unaware of the existence of such an industry (Mulcahy, 2007).

The current international guidelines are designed to ensure that children (with limited consumer knowledge and developing critical faculties) are not deceived by the true intent of a commercial message. Thus, internet advertising to children should be distinct from content and should be clearly labelled with “advert” or “ad”. Regulation also provides that any links from a host site to an advertiser's site should be well signposted, e.g. “you are now leaving our site”. Wording which implies an artificial scarcity or urgency, e.g. “buy now”, “only available for 2 days” is discouraged as is the use of popular characters or celebrities to link to commercial activity. Children can develop strong attachments to characters they encounter on TV (e.g. The Teletubbies), in comics and magazines (e.g. Denis the Menace), in books (e.g. Harry Potter), in movies (e.g. The Incredibles) and even through pure merchandising (e.g. Barbie). As children are less able to distinguish fantasy from reality their “loyalty” to a favourite character can be exploited if that character is endorsing a product.

In summary, despite a fast-changing somewhat amorphous international regulatory environment, there appears to be general agreement that commercial activity directed at children on the internet should avoid a number of specific practices which can lead to physical, mental or moral harm or which can result in deception. We now turn to our empirical study which was designed to ascertain to what extent the sites visited by today's UK children operate within these principles.

Methodology

The research consisted of four stages: structured observation of sites; in-home observation of friendship pairs; child focus groups and parent focus groups. Research assistants conducted the site observation, while the qualitative fieldwork was carried out by ChildWise, a market research agency specialising in children. They have a network of nationwide recruiters which allowed the sample to be drawn from across the country and from different socio-economic groups.

Structured observation

A question on a larger survey by the author (Nairn et al., 2007) had established the 40 web sites most popular with over 500 UK children. A nationally representative survey of children in the same year confirmed the popularity of these sites (ChildWise, 2007-2008). These 40 sites were used for the observation exercise. It should be noted that if this research were conducted again to-day social network sites such as Bebo, MySpace and Facebook would feature more prominently, (ChildWise, 2007-2008). Two previous studies (Nairn and Dew, 2007; Nairn and Monkgol, 2007) had classified the sites into categories as shown in Table I.

Three research assistants each assessed the 40 sites, completing a standard questionnaire designed to ascertain whether the sites adhered to the general principles shown earlier in this paper. As many sites display a large number of adverts (up to 17 on a single page) which can change with each page impression it was clearly an almost limitless task to evaluate each advert encountered in detail. The first three adverts appearing on each site were therefore selected for in-depth analysis. Thus while 211 adverts were evaluated for general adherence to principles of good practice, the content and presentation of 70 were scrutinised in more detail. The three research assistants conducted their site evaluations separately and then the principal researchers checked for consistency before a final discussion with the assistants. Any anomalies were resolved by revisiting the sites. The study considered the three internet business models: sale of merchandise, sale of advertising space and sale of information. However, due to space constraints only the findings on merchandising and advertising are presented in this paper. Sale of information and privacy issues are considered elsewhere (Nairn and Monkgol, 2007).

Qualitative research

In home observation of friendship pairs navigating favourite sites was conducted with 16 children age 7-15. These observations were videoed. Watching children navigate the internet in a relatively natural setting allowed greater insight into their behaviour. The children were given some guidance (e.g. go onto one of your favourite games sites) and then asked about their navigations. In order to gain insights from an additional peer setting, four in-school focus groups were held with a total of 24 children from years 3 (age 7 and 8), 6 (age 10 and 11), 7 (age 11 and 12) and 10 (age 14 and 15) and four focus groups with 30 parents of children from both primary and secondary school. Children in the age range 7-16 were included in the study. It was felt that below this age children would not spend a great deal of time on the internet (although similar subsequent US research has been conducted with children between 2 and 8 (Buckleitner, 2008)). We also wanted to include children from the upper age limits considered by current regulation.

The sample of both children and parents was structured to cover age, gender, geographical location and social class. The children all used the internet at home at least three times a week and half had internet access in their rooms. The children from the focus groups were asked to complete a pre-group diary recording internet use for the preceding week and paper copies of screenshots were used as discussion prompts. Three of the parents' groups were with heavy internet users and one group with light users.

Discussions guides again focused on purchasing and advertising and followed the general principles in detailed above.

Analysis

The site analysis questionnaires together with transcripts and videos from the in-home observations and focus groups formed the basic data set. The data from all stages of the research are brought together and reported below in relation to the two general principles identified from regulation: harm and deception. We consider how both merchandising and advertising activity comply with current guidelines. In terms of merchandising we consider the sale of goods or services either by the site itself or with the help of a specialist online retailer. Examples include virtual goods such as software upgrades, ringtones and enhanced games facilities (e.g. furniture for your Club Penguin igloo or branded fashion to dress up the Sims); and physical own-brand merchandise such as Neopet's cuddly toys or Barbie accessories. In terms of advertising we consider third party advertising on virtual space purchased from the host-site, e.g. a film or mobile phone package advertised on a gaming site such as Miniclip.

Physical, mental and moral harm

Best practice precludes offering children illegal and dangerous products or using violent or sexual imagery in a sales or advertising context. Of the 70 adverts analysed in detail, 25 percent contravened the guidelines. 9 percent promoted gambling, 4 percent intimate dating, 6 percent credit, 3 percent surgical treatment and 3 percent driving related services. While adverts for age restricted products such as cars and motor insurance are irrelevant rather than harmful, gambling, sexually provocative dating services, credit and cosmetic surgery clearly run contrary to principles of protection. The children in our research were particularly disturbed by the sexual content as one 10/11 year old boy told us, “it has this lady on, it was rather embarrassing to watch.” In fact, he was too embarrassed and guilty to tell his parents, “I don't tell my mum or dad, because they'll say something like, why did you click on it?”

Parents' primary concern was what they saw as the growth of loans and gambling adverts. One father of a primary school child put it like this:

It's too easy to sit and do it online. Maybe my son might keep seeing that poker and eventually he's going to get to the stage where he'll have a credit card and he might think I'll just go and have a look in there and that could be the rest of his life down the toilet.

Another father of older children said:

I don't think a site should be run entirely on ads for loans and gambling...because as far as I'm concerned they're the lowest of the low. There's too much debt.

The finding that a quarter of adverts on children's favourite sites could be classified as harmful is, on the face of it, extremely worrying. However, a close inspection of the nature of the sites enjoyed by children shows that less than one-third are actually designed with an under-18 audience in mind. As seen in Table I, 30 percent of sites are general entertainment sites such as YouTube and Albino Blacksheep; a further 18 percent are gaming sites aimed at adults as well as children (e.g.Mousebreaker and Fingertime); while the remaining fifth are primarily social networking sites and search engines (Bebo, Yahoo!, etc.). This means that rather than marketers deliberately targeting children with dating, driving and debt advertising space and merchandise on most sites is probably targeted at an audience of young adults.

Pester power

The 30 percent of sites specifically created for children and unlikely to attract an adult audience (Neopets, Barbie, etc.) did not sell age-restricted products or use sexual or violent imagery in either merchandising or advertising. They did however fail to protect from one form of harm: pester power. Two of the sites investigated are essentially entertaining shop fronts for children's brands: Barbie and Diddl. Both of these sites constantly offer children the opportunity to create wish lists which can be quickly and easily e-mailed to parents and other adults. While technically the sites do not use the words “tell your mum to get it” (EU, 2005) the spirit behind e-mail wish lists is the same. The parents we talked to were well aware of wish lists. Some found the practice rather mercenary, as one mother of a seven-year old girl said:

My daughter's done the Bratz one (wish list). It's cute and all that...But it's cynical as well...It takes the surprise out of gifts....

Others alluded to the disagreements:

…she'll call me to look and I'll say “add the postage and packaging on it and no you're not having it” …they think you're a money tree.

One of the seven year old girls said during the discussion of wish lists, “I'd ask my mum and if she said no I'd keep asking and go on my knees.”

We found no evidence on any of the sites of direct implications that purchasing a product or service would increase a child's appeal to the peer group.

It is clear from our research that the sites visited by children do contain commercial material which is “harmful” under the terms of international regulations. While wish lists require attention from sites deliberately targeting children, the other forms of harm are more problematic to address as they are perpetrated by sites which, although they attract children, are not necessarily set up with a child audience in mind. This presents particular challenges to on line commercial agents and regulators which will be considered in the recommendations section.

Deception

The second generally agreed principle for commercial internet messages aimed at children is that the format and content should not be deceptive: i.e. the child should clearly understand the selling or persuasive intent of the originator of the message and be in a position to reject the message if she so chooses. As noted earlier, six good practice guidelines exist:

advertising should be distinct from content;
it should be clearly labelled;
links from the host site to an advertiser's site should be clearly indicated;
links should not be signposted by a character or celebrity;
artificial scarcity or urgency should not be implied; and
characters should not endorse products when they are part of the adjacent entertainment.

Under these terms of reference, the advertising investigated could only be described as extremely deceptive. Only 37 percent of the adverts encountered were labelled with “advert” or “ad” and almost a quarter of all adverts (21 percent ) were integrated or embedded into the content. For example, on Cartoon Network out of a row of identical-format picture buttons some clicked to games and others to adverts. These hidden commercial messages could be detected both on sites specifically for children and those for a more general audience. It seems that in the absence of widespread labelling, children have been socialised into expecting non-uniform advertising formats and they gradually acquire skills to distinguish commerce from entertainment as they grow older. The seven and eight year olds (in Roedder John's perceptual of analytic groups) identified advertising by its physical position on screen (“I get them at the bottom of the page.”) or by its movement. The 11 and 12 year olds, just entering the reflective stage, began to consider content as well as format, “it's got nothing to do with the games, so you know it's an advert.” They also began to understand intention “It's popping up if you know what I mean. Trying to attract you.” However, even at this age spotting an internet advert poses a challenge. When one group of 11-12 year old girls were presented with a screen and asked to count the adverts the answers ranged from one advert to six.

As children's cognitive and social capacities develop they begin to understand persuasive intent and tactics, so 15 year old boys noted: “I think on the internet, it's much more subtle” (than on TV) and “sometimes they blend in, so it looks like it's on your computer”. However, one advertising format deceived even the most media savvy young people: advergames. An advergame consists of embedding brand messages in colourful, fun and fast paced games (Kaiser Family Foundation, 2006) which create sticky content on brand sites (e.g. a Froot Loops game on the Kellogg's site) or are paid-for and placed on host sites (e.g. Disney embedding a film related advergame on Miniclip). According to US research (Kaiser Family Foundation, 2006) most children think that these product-centred games are just games, not mainly advertisements, failing to understand their persuasive intent. Our research bore this out. When an advergame for Persil appeared, a 15/16 year old boy said categorically, “that's not an advert because it says play.” His friend finally noticed the word “ad” in tiny print and the boy felt let down, “it tricks you in the game”.

Parents also felt the volume and covert nature of internet advertising was deceptive. As one mother of teenagers said:

You don't know whether it's taking away their ability to choose, you know subconsciously. So many messages go into your head that when you come to make a choice what do you bring to the front of your mind, that what's being shoved at you.

A good deal of advertising on children's internet sites clearly contravenes good practice guidelines to protect from deception. Many of the deceptive adverts are for products which will not be purchased immediately on-line but at some future date in a high street retail outlet. However, we also found deceptive tactics used to generate more immediate sales. In every focus group (parents and children) dubious offers which attracted attention with the words “free” or “win” were discussed.

The ones really to worry about are the “get £10 free” or “get a free phone”. It's those which are misleading (Dad of teenagers).

Children had all either been deceived or knew someone who had. The oldest of the children (15-16) agreed that even though they can see through some of the deceptive tactics when they concentrate on it, they could still easily be fooled. A discussion of an advert for a software game illustrates.

Boy 1. “The title is quite misleading because it says free games“

Boy 2. “(The price) seems to be a lot smaller. Send your mobile stands out more because it's red, but this (price) is hidden away a bit.”

Boy 1. “The thing is with the site, it says for free as well, so you might be less likely to look for the amount of money, the price. You might just text your number.”

Web sites encouraging impulse purchases using phones are a particular problem as one 11-12 year old girl found out to her cost, “I had £10 credit and I went on this web site to get a ring tone and it took all my money.” She was referring to the Jamster scam where children thought they had bought just one ringtone when in fact they had technically agreed to a subscription for a series of downloads. Parents in all groups felt their children had been victims of quick pressure sales techniques for what many of them felt were “pointless purchases” such as virtual items for a Habbo Hotel room or furniture for a Club Penguin igloo.

The companies are smart in a sense. They know a child is going to pick out certain things, like dial this phone number and you'll automatically get x amount of credits on your account (Father of primary school child).

In fact the effects of new payment methods such as using a mobile phone on responsible marketing to children is an issue which is currently not well addressed in guidelines but which emerged strongly during our research. Several of the sites we inspected (Fingertime, Cartoon Network, Stardoll, WWE and Runescape) not only encouraged payment by mobile phone credit but also by Solo cards which can be held by 11-year-olds. Restricting payment method to credit cards provides a check against children being persuaded to make an impulse purchase with no parental involvement. When Solo cards are accepted this safeguard is removed. This situation is likely to be exacerbated by the introduction of pay-as-you-go cards from Visa and Mastercard (see www.mycashplus.co.uk/) which can be purchased online and topped-up at the Post Office. This issue has already been taken up by the Children's Charities Coalition on Internet Safety (2007).

Conclusion

A total of 40 sites popular with children were inspected and their commercial content discussed with a range of young people and parents across the country. By and large the internet is a safe, exciting and stimulating environment for children. However, it is also clear that current regulations to protect children from the risks of harm and deception from online commercial agents need to be tightened and more rigorously enforced or self-policed. One of the most important findings is that 70 percent of sites visited by children are not created with a child-only audience in mind. The advertising space and merchandising activity is therefore often unsuitable. The majority of TV programmes watched by children are, of course, also viewed by adults but the existence of the watershed is one attempt made to protect children. Of the adverts encountered across sites, 25 percent were for dating, gambling, credit, surgery and age-restricted products and services. Children were upset by intimate dating material and parents worried about the long-term impact of ubiquitous incitement to borrow and gamble. Advertising on sites specifically targeting children was often unfair and deceptive. Almost three-quarters of adverts were not labelled and over one-fifth hidden in the site content. While children gradually learn how to tell entertainment from commerce the true nature of advergames was not even understood by 16 year-olds. “Free” offers were prolific and many employed pressure tactics to urge children to buy immediately using mobile phone or solo cards.

Recommendations

The first recommendation is for surveys such as this to be carried out on a regular basis. Since this research was conducted new commercial tactics have appeared such as Facebook's “Beacon” programme which uses behavioural data to inform members of purchases made by their friends (“Jenny just bought a Gucci bag”). It is unlikely that a child would realise that this is a sales tactic. Moreover, this tactic is manipulating friendships for commercial gain which stand counter to guidelines on peer pressure. Bebo has also begun selling space for product placements in its soap opera “Kate Modern”. Given that even teenagers have problems with advergames it is unlikely that the majority of children would be able to evaluate the intention behind product placements. The regulatory environment will also continue to evolve and it is thus important for those both involved in doing business with children and looking after them to keep pace. Focusing the debate on advertising in its strictest sense may obscure a range of other evolving commercial practices.

The second recommendation relates to the finding that most sites enjoyed by children are also visited by adults. Sites should maintain an updated profile of their audience through regular surveys. Attention should then be paid to section 54.4 of the ASA CAP code (2005) which currently covers betting and gaming: “No medium should be used to advertise betting and gaming if more than 25 percent of its audience is under 18 years of age.” This 25 percent guideline could usefully be applied to advertising of other categories such as dating, surgery, loans and credit cards. When sites realise they are attracting a large proportion of children, their advertising strategy should be amended accordingly.

Adverts should all be clearly labelled as such and this should apply to all formats including advergames. There should be a minimum font size so that the labelling does not go unnoticed. In addition adverts should be placed in a specific place on the page so that children immediately know where the commercial content is, rather than having to learn the ever-changing rules of the game as they acquire more experience and greater cognitive facilities. It is true that children become more savvy the more experience they gain with a commercialised internet culture. However this does beg the question of why should they have to learn to navigate a deceptive environment? Might it not be more socially desirable to make the relationship between entertainment and persuasion for commercial gain more transparent for children of all ages?

Finally, most regulation of commercial activity on children's internet sites is voluntary, but where statutory provisions are made, e.g. The Unfair Commercial Practices Directive (2006, p. 23) these should be rigorously enforced. This would include imposing bans on wish lists and other practices designed to encourage pester power and on the widespread practice of “falsely creating the impression of free offers”.

Finally, the business case

Companies who take care to include commercial content which is neither harmful nor deceptive on internet sites used by children are likely to find an enthusiastic welcome from an audience which is, after all, the consumers of the future. The children we talked to overwhelmingly found hard sell tactics (whether overt or sneaky) deeply annoying (see Figures 1-3 for examples of screen grabs found on web sites for children and young people). Companies should first of all make it clear to children that advertising pays for free content. Currently children do not understand this:

Every 15 minutes on telly, 3 minutes of advertising are on. Why do you need it on a computer as well as on TV?! (10 year old boy).

Care should also be taken not to allow advertising to intrude into children's online activities:

They just flash and make you want to click on them.

Yes, you're trying to play a game and it's in your eye (11-12 year old girls).

I hate ones like that, they come up on screen … and you can't get rid of them … they come up at the last level of a game and then you die (11 year old boy).

Finally, children really do not want to be pestered at every turn by companies peddling their wares like persistent street hawkers. To quote the girl from whom the title of this paper is taken:

… it does my head in...buy it, buy it, buy it!

Figure 1Example of good labelling practice

Figure 2Example of advergame

Figure 3example of free offers annoying to children and worrying for parents

Table IClassification of sites in Research

References

Anderson, C., Gentile, D., Buckley, K. (2007), Violent Computer Game Effects on Children and Adolescents: Theory, Research and Public Policy, Oxford University Press, Oxford, .