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We see it every day: children in elementary and middle school using tablets and smartphones to access apps and games. Often these children are unsupervised while they are using the device, which makes us wonder “who is making sure that child isn’t doing something they shouldn’t be doing?” Hopefully the parents of the children we see in those situations have taken some precautions that we cannot see, like setting restrictions on the device or knowing exactly what apps and games are available on that device at all times, but even the most tech savvy parents struggle with setting those limits. Kids and teens are asking for personal devices, like smartphones and tablets, earlier than ever, and with those devices come a lot of other issues that parents need to be ready to face.
I spend much of my time traveling to schools in South Carolina where I often host sessions for parents to help them understand technology better and learn how to help their children navigate the digital landscape more effectively. One of the questions that I receive most often is “how old should my child be before they can [insert any technology-based activity here]?” I get this question so often that I’ve begun to incorporate it into the presentation just so parents don’t have to ask me every time. While there are a lot of great guidelines out there to help us answer this question, it is a difficult one to answer. Parents love clear, decisive answers to questions, but unfortunately not all questions have these kinds of answers. Today we are going to focus on Social Media specifically, but we’ll touch on some other issues as well.
Social Media and COPPA
Most Social Media sites, including Facebook, Instagram, Snapchat, Twitter, and many others, require that their users be at least 13 years old before they can create an account and use the site or app. This age requirement is the decision of the app developer, but most companies abide by this rule in order to comply with COPPA, the Children’s Online Privacy Protection Act. COPPA was enacted by Congress as a way to protect the information of children less than 13 years of age, and it was issued and is enforced by the Federal Trade Commission. It was originally passed in 1998 and took effect in 2000, with a later amendment taking effect in 2013. The Act is lengthy, but the core ideas are outlined by the FTC below:
The primary goal of COPPA is to place parents in control over what information is collected from their young children online. The Rule was designed to protect children under age 13 while accounting for the dynamic nature of the Internet. The Rule applies to operators of commercial websites and online services (including mobile apps) directed to children under 13 that collect, use, or disclose personal information from children, and operators of general audience websites or online services with actual knowledge that they are collecting, using, or disclosing personal information from children under 13. The Rule also applies to websites or online services that have actual knowledge that they are collecting personal information directly from users of another website or online service directed to children. Operators covered by the Rule must:
- Provide direct notice to parents and obtain verifiable parental consent, with limited exceptions, before collecting personal information online from children;
- Give parents the choice of consenting to the operator’s collection and internal use of a child’s information, but prohibiting the operator from disclosing that information to third parties (unless disclosure is integral to the site or service, in which case, this must be made clear to parents);
- Provide parents access to their child’s personal information to review and/or have the information deleted;
- Give parents the opportunity to prevent further use or online collection of a child’s personal information;
- Maintain the confidentiality, security, and integrity of information they collect from children, including by taking reasonable steps to release such information only to parties capable of maintaining its confidentiality and security; and
- Retain personal information collected online from a child for only as long as is necessary to fulfill the purpose for which it was collected and delete the information using reasonable measures to protect against its unauthorized access or use.
How do they know the age of the user?
Most social platforms willingly enforce this rule as to avoid any issues from the beginning, but not every social platform tackles this problem head on. Some platforms, like Facebook and Ask.FM, ask users their date of birth or age as a part of the registration process, refusing any users who identify themselves as under the age of 13. Other platforms, like Twitter and Instagram, inform users that by creating an account that they agree to the terms and conditions of the platform, which includes being 13 years of age or older, but the platform never explicitly asks the user to provide their date of birth or age.
Unfortunately, child users do not know that they shouldn’t use the platform if they are under the required age, and the information is never clearly presented to them. I speak directly to elementary and middle school students on a regular basis and often when I ask “How old do you need to be to use Social Media apps, like Instagram and Snapchat?” I am met with answers that range from “eight” to “twenty-one!” While we know that children would most likely ignore this requirement and create the account regardless of their age, it still removes an opportunity for the children and parents to make a more informed decision on what social platforms their children should access.
So what information does COPPA prohibit websites and apps from collecting? Again, the FTC outlines this information for us below:
The amended Rule defines personal information to include:
- First and last name;
- A home or other physical address including street name and name of a city or town;
- Online contact information;
- A screen or user name that functions as online contact information;
- A telephone number;
- A social security number;
- A persistent identifier that can be used to recognize a user over time and across different websites or online services;
- A photograph, video, or audio file, where such file contains a child’s image or voice;
- Geolocation information sufficient to identify street name and name of a city or town; or
- Information concerning the child or the parents of that child that the operator collects online from the child and combines with an identifier described above.
What is interesting about this information is that is doesn’t only apply to information that the platform requests of its users, but it also applies to all of the information that the users willingly or voluntarily share. This means that if your child shares a picture of themselves, an audio file with their voice, or a piece of geolocation data, then the company has technically violated COPPA if they knew, or had reason to believe, that the user was under the age of 13. These are companies that manage millions of users daily, so trying to turn their attention to specific accounts based on age is difficult. The companies typically do their best to respond to reported violations, but since these issues are managed on a case-by-case basis, it is unlikely that any sweeping action or reform is coming soon.
Digital Parenting Takeaway
Most Social Media platforms require that their users be at least 13 years of age in order to register and use their service, primarily because the information that they will likely share is also likely to violate the Children’s Online Privacy Protection Act. Luckily, this makes decisions for parents relatively easy, in that the children just aren’t allowed to use the platform or else they violate the rules, but this argument may not easily convince your child that they don’t need to access the platform. Instead of adhering to a rule that you had no hand in creating, try these 3 different techniques:
Try Social Media with your children.
Just because they aren’t allowed to create an account and share their information online doesn’t mean that they can’t participate. By downloading and using a social media platform you can help model the proper behavior for your children before they have access to a similar platform on their own. Make videos, take pictures, and explore social media as a team through your account, that way you have control over the content that is published and the communication that might take place as a consequence of that material being placed online.
Look for other ways for your children to be online safely.
Social Networks aren’t the only way that children can go online and feel like they are interacting with others. Online games made specifically for younger children offer the opportunity for them to communicate with others without having to provide any personal information or details. Also, your child’s school may use classroom-based tools that mimic social media, which allows them to get the experience of communicating with other users online without putting themselves at risk.
Talk to them about Social Media safety long before you give them access.
Let’s face it: your kids are going to do things you don’t want them to do. This might mean that they decide to get on Instagram or Musical.ly without telling you. This could be at a friend’s house or through someone else’s device. If you haven’t taught your children how to stay safe online then they could still be making a lot of these mistakes and now, even worse, you won’t even know about it. By talking to them early and often about these issues, we can help ensure that even when they break some of the rules that they will still remember how to prioritize their safety and privacy.