This project, conducted and developed in by Open Evidence Staff in consortium with London School of Economics and Political Science and Block de ideas SL aims to “support the Commission with evidence for investigating and understanding the new and dynamic channels of online marketing to children, as well as the measures to alleviate consumer vulnerability among children in relation to sophisticated online marketing”. In addition, only if justified by the evidence gathered, the study should also “help the Commission in preparing evidence-base proposals for new policy measures”. More in general, the study shall test and assess the awareness and understanding by children in different age groups of sophisticated marketing techniques directed at them in OGSMMA, taking into account that European Commission has currently identified nine problematic marketing practices:
(1) Embedded advertising (or advergames). The practice of blending advertising messages with interactive games and competitions makes it more difficult especially for children to discern the marketing element;
(2) In-app and online game purchases. In mobile applications and online games marketed as “free”, players can typically only access portions of these games for free, with new levels or features, such as faster game play, costing money. It can be difficult for children to understand that even though you have downloaded a free app, you still might have to pay additional real money during the game;
(3) Data privacy issues/ market research content. When children buy goods and services, especially over the Internet, they are commonly asked to give a number of personal details about themselves. However, it can be difficult for children to see what the consequences of giving out personal data are, and it may be unclear how the seller uses the information;
(4) New wallet (credit cards, phone as wallet). When children today purchase apps, music and entertainment over the Internet or mobile phone this often happens with a variety of payment means, such as value codes (for iTunes), parent’s debit or credit cards or via (mobile) telephone bills. This means that children’s experiences with “real” money have become more intangible and their understanding of the implications of spending money is diminished;
(5) Lack of price and contract transparency. Even adult consumers are often having trouble figuring out what things cost online, what is included in the price, what the duration of the contract is, etc. In the case of children this situation may be compounded by lack of reasoning skills and purchasing experience;
(6) Lack of age verification systems. Some online games have an age limit of for instance 12 or 13 years to sign up. At the same time, there are usually no age verification systems on the site;
(7) Lack of contact information about the suppliers. There is often a lack of contact details where one can ask for information or complain if something happens on websites. Some online games where children can make purchases with mobile phones or credit cards, do not have any complaints possibilities or follow up mechanisms;
(8) Alcohol advertisement. Advertisements of alcohol in social media sites and in other websites popular for children also represent an area of concern in the context of online marketing. Hidden Internet advertising that is not covered by the UCPD directive occurs in the form of comments posted on social networks, forums and blogs;
(9) Inappropriate contents. Websites specifically targeting children may require different sets of rules. On such pages the level of protection against problematic advertisement should be checked, as parents and children trust that these websites are safe spaces. It is important to not only look at the way in which advertisement incites children into making purchases on these sites, but also on the content and appropriateness of advertisement.
Within this context, the study tackles the following questions:
- What are the most common, effective and questionable techniques in OGSMMA to impact children consumer behaviour?
- To what degree and how these techniques influence the consumer behaviour of children?
- To what degree are children recognise/understand implications of embedded marketing?
- How to identify experimentally the average behaviour and skills and specific source of susceptibility with regard to problematic practices?
- To what degree are parents able to recognised/understand implications of embedded marketing?
- To what degree and how parents try to regulate the online commercial activities of their children?
- How to map/classify the policy interventions in place in Member States and at EU level to alleviate children’s vulnerability?
- How to identify and test the most effective interventions to mitigate children’s vulnerability vis-à-vis embedded marketing?
- How to identify unfair practices in OGSMMA aimed at children, and substantiate why they are unfair?
- What are implementation barriers for effective measures that may alleviate children’s vulnerability?
- Which recommendations can be extracted from the study?
- How can the study suggest revisions/ expansion of UCPD and AVMSD with relation to ‘vulnerable children’?
To address these questions five tasks have been planned.
► Task 1: Preparatory Phase. This phase comprises a systematic review of the scientific literature; the identification of problematic OGSMMA practice; the taxonomy of current protective measures; in-depth analysis of 25 OGSMMA and the selection of measures to be tested. This preparatory phase includes consultation with different stakeholders.
► Task 2: Experimental Phase. The previous phace will give us insights to design an experiment to test whether or not certain marketing practices influence children behaviour and whether or not children are aware of, and recognise, such practices. In other words we will test whether or not a given cause (practice or protective measure) has an impact that is statistically significant on a given effect (awareness/recognition). EC currently mentioned the following protective measures: a) customer identification and age verification systems; b) warning with a recommendation for the age of the users when signing up; c) need of parental approval when signing up; d) self-limit setting (for spending time and money); e) more official lay out webpages when making a purchase; f) warning signs when making purchases; g) visible signs popping up on player screen displaying length of play and money spent in game; h) Possible new measures that can serve to protect children vis-à-vis problematic online marketing practices, as identified in the preparatory phase. Yet, the statistically significant coefficients a randomised control trial experiment gives us do not by themselves how and why a given treatment (cause) produces a given outcome (effect). More in depth ethnographic analysis based on direct observation of and interaction with, the children as they real games would give us more insights on the processes and explanatory mechanisms to complement the results of the experimental labs. Triangulation between experimental and ethnographic findings will produce articulated and more complete answers to the questions listed above.
The sample will be recruited from two age groups: 7-8 and 11-12 from a school opportunely selected in an urban areas (Barcelona and London) as to ensure mixed SES backgroun. At the very beginning children will be given an endowment of a virtual good (an equivalent of money) and it will be explained to them that they can spend this good during the game but also that at the end of the game the amount retained of this good can be exchanged for some toys or other in kind incentives. As anticipated, most sessions will be conducted in the schools and we will present children with a game, which we will select either from commercially available games or from open-source or independently created games. We will use our software to interact with the program and intercept the critical points in which the experimental manipulations appear (e.g. by having a TCP-IP communication channels between the two programs).
► Task 3: Focus groups. These aim to understand how individuals (parents and kids) experience the issues of study and what significances they attribute to a specific product or service. In other words, we intend to provide “insights” about the “human” side of an issue, that is, the often contradictory behaviours, beliefs, opinions, emotions, and relationships of individuals. The scope of the focus groups includes not only alcohol advertisement but also other problematic OGSMMA practices. We will conduct 16 focus groups in the eight different countries (France, Germany, Hungary Italy, Poland, Spain, Sweden, and UK), in the form of 2 simultaneous groups per evening: 1 adult group in one room + 1 children group in a separate room (parents and their kids).
► Task 4: Parents online survey. This survey will be carried out in 8 countries (France, Germany, Hungary Italy, Poland, Spain, Sweden, and UK) targeting 800 respondents (parents/guardians of children) per country (N=6400) through a random sample drawn from online panel representative of the online population.
► Task 5: Analysis and Recommendations. The recommendations produced by our approach will be evidence-based but also informed by policy compatibility and technical feasibility and will take into account on-going debates and regulatory and policy differences existing among European countries. Moreover, as an addition not included in the Technical Offer and provide at no costs for the study budget we plan to maintain close contacts with regulators and industry and to organise at our expenses a validation workshop with the Commission, with representatives of Member States regulator, and with representatives of industry to validate the implications we draw from the analysis of findings as to move from them to final policy recommendations.