The Children’s Advertising Review Unit (CARU) was formed by the National Advertising review Council (NARC) in 1974. CARU is a self-regulated program that promotes responsible children’s advertising.

CARU’s basic activities are the review and evaluation of child-directed advertising in all media, and online privacy practices as they affect children. When these are found to be misleading, inaccurate, or inconsistent with CARU’s Self-Regulatory Guidelines, CARU seeks change through the voluntary cooperation of advertisers.

CARU’s Guidelines contain a section that highlights issues, including children’s privacy, that are unique to the Internet and online sites directed at children age 12 and under. The following is an overview of these guidelines:

1. Advertisers must clearly disclose all information collection and tracking practices, all information uses, and the means for correcting or removing the information. These disclosures should be easily accessible before any information is collected.

2. Advertisers should disclose why the information is being requested and whether the information will be shared, sol or distributed outside of the collecting company. This disclosure should be written in language easily understood by a child.

3. Advertisers must obtain prior “verifiable parental consent” when they collect personal information (such as email addresses, screen names, addresses or phone numbers) that will be publicly posted. The definition of “verifiable parental consent” in the Children’s Online Privacy Protection Rule applies.

4. For activities that involve public posting, advertisers should encourage children not to use their full names or screen names that correspond with their email address, but choose an alias (e.g., “Bookworm,” “Skater,” etc.) or use first name, nickname, initials, etc.

5. Advertisers should not require a child to disclose more personal information than is reasonably necessary to participate in the online activity (e.g., play a game, enter a contest, etc.).

6. When an advertiser collects personal information only for its internal use and there is no disclosure of the information, the company must obtain parental consent, and may do so through the use of email, coupled with some additional steps to provide assurance that the person providing the consent is the parent.

7. To respect the privacy of parents, advertisers should not maintain in retrievable form information collected and used for the sole purpose of obtaining verifiable parental consent or providing notice to parents, if consent is not obtained after a reasonable time.

8. If an advertiser communicates with a child by email, there should be an opportunity with each mailing for the child or parent to choose by return email or hyperlink to discontinue receiving mailings.

9. When performing age-screening, advertisers should ask screening questions in a neutral manner so as to discourage inaccurate answers from children trying to avoid parental permission requirements.

10. Since hyperlinks can allow a child to move seamlessly from one site to another, operators of Websites for children or children’s portions of general audience sites should not knowingly link to pages of other sites that do not comply with CARU’s Guidelines.

Resources: www.caru.org