Privacy Policies on Kids’ Favourite Web Sites

Privacy Policies on Kids’ Privacy Policies on Kids’ Favourite Web SitesFavourite Web Sites

Jacquie Burkell, University of Western OntarioJacquie Burkell, University of Western Ontario

Valerie Steeves, University of OttawaValerie Steeves, University of Ottawa

Children’s Online Privacy Children’s Online Privacy Protection ActProtection Act

Sites directed at childrenSites directed at children

Privacy policyPrivacy policy

Verifiable parental consent for children Verifiable parental consent for children

under 13 years of ageunder 13 years of age

Personal Information Protection Personal Information Protection and Electronic Documents Act and Electronic Documents Act

Consent-based information regimeConsent-based information regime

Openness about information practicesOpenness about information practices

Legal guardian can consent for minorLegal guardian can consent for minor

Is Web Use Supervised?Is Web Use Supervised?

COPPA and PIPEDA provide for andCOPPA and PIPEDA provide for and even assume parental involvement foreven assume parental involvement for consentconsent

BUT, in 2005…BUT, in 2005… only 13% of children surveyed are “mostly” only 13% of children surveyed are “mostly”

with an adult when using the Internetwith an adult when using the Internet Among the youngest respondents (grades Among the youngest respondents (grades 4-5), 73% are “sometimes” or “usually” alone 4-5), 73% are “sometimes” or “usually” alone

when they use the Internetwhen they use the Internet

Transparent Transparent Information Information Practices Practices

+ Voluntary Disclosure

= Informed consent

OverviewOverview

How accessible are privacy policies onHow accessible are privacy policies on

the sites kids visit?the sites kids visit?

How easy are they to understand?How easy are they to understand?

Kids’ Favourite SitesKids’ Favourite Sites

• 5,272 kids• 2,800 favourite sites

• Over 25% picked Neopets

• Over 25% picked Addictinggames

Kids’ Favourite SitesKids’ Favourite Sites Game sitesGame sites Multimedia/streaming sitesMultimedia/streaming sites Special interest sitesSpecial interest sites Shopping sitesShopping sites Television sitesTelevision sites

Only 1% were sites directed at children Only 1% were sites directed at children

The Top 50 SitesThe Top 50 Sites

Represent over one-half of all choicesRepresent over one-half of all choices 50 of 50 (100%) are commercial sites50 of 50 (100%) are commercial sites 45 of 50 (90%) ask kids to register45 of 50 (90%) ask kids to register 47 out of 50 (94%) collect personal47 out of 50 (94%) collect personal

informationinformation 48 out of 50 (96%) have privacy policies*48 out of 50 (96%) have privacy policies*

* As of September, 2005; one additional site has added a privacy policy since * As of September, 2005; one additional site has added a privacy policy since that datethat date

An accessible policy is …An accessible policy is …

Linked directly from the home pageLinked directly from the home page

Immediately visible on the home page Immediately visible on the home page

Emphasized to be highly visibleEmphasized to be highly visible

Clearly labeled to identify contentClearly labeled to identify content

Is there a privacy policy?Is there a privacy policy?

48 of 50 (96%) have a link to a privacy48 of 50 (96%) have a link to a privacy

policypolicy

1 site has a ‘dead link’1 site has a ‘dead link’

1 site has no link, no policy1 site has no link, no policy

How many links to the policy?How many links to the policy?

3 websites with 2 links to the policy3 websites with 2 links to the policy

45 websites with 1 link45 websites with 1 link

1 website with a link, no policy1 website with a link, no policy

Can you see it immediately?Can you see it immediately?

First page, no scrolling: 21First page, no scrolling: 21

1,2, or 3 screenlengths of scrolling: 181,2, or 3 screenlengths of scrolling: 18

More than 3 screenlengths scrolling: 9More than 3 screenlengths scrolling: 9

1 site has a link, but not on the home1 site has a link, but not on the home

pagepage

Where is the link?Where is the link?

Top: 7Top: 7 centre: 2centre: 2 right: 5right: 5

Side Navigation: 2Side Navigation: 2

Bottom: 39 Bottom: 39 centre: 29centre: 29 left: 10 left: 10

Not on home page: 1Not on home page: 1

How visible are the links?How visible are the links?

Unique, highly visible: 5Unique, highly visible: 5

Primary navigation/Key link: 3Primary navigation/Key link: 3

Secondary navigation: 16Secondary navigation: 16

Fine Print: 22Fine Print: 22

Minimized: 3Minimized: 3

How are the links labelled?How are the links labelled?

47 of the 49 links use the word ‘privacy’47 of the 49 links use the word ‘privacy’ PrivacyPrivacy Privacy policyPrivacy policy Safety and privacySafety and privacy

2 of the 49 do not2 of the 49 do not Terms and ConditionsTerms and Conditions LegalLegal

Doing it right: Doing it right: CandystandCandystand KazaaKazaa

Making it hard to find:Making it hard to find: NewgroundsNewgrounds

The rest of the picture…The rest of the picture…

Getting to the policy is only the first stepGetting to the policy is only the first step

Privacy policies must be understood byPrivacy policies must be understood by

the usersthe users

An understandable policy is…An understandable policy is…

Relatively shortRelatively short

Written at an appropriate reading levelWritten at an appropriate reading level

Easy to navigate, with appropriate sub-Easy to navigate, with appropriate sub-

headingsheadings

Self-contained (does not require linkingSelf-contained (does not require linking

out)out)

How long are the policies?How long are the policies?

Average word count: 1902Average word count: 1902 Minimum: 121Minimum: 121 Maximum: 6414Maximum: 6414

What is the reading level?What is the reading level?

Flesch Reading Level (60-70 is acceptable forFlesch Reading Level (60-70 is acceptable for adult readers, higher is better)adult readers, higher is better)

Average: 36.32Average: 36.32 Best: 58.9 (ebaumsworld)Best: 58.9 (ebaumsworld) Worst: 23.3 (flowgo)Worst: 23.3 (flowgo)

Flesch Reading Level (Grade 8 is acceptableFlesch Reading Level (Grade 8 is acceptable for adult readers)for adult readers)

Average: 11.66Average: 11.66 Minimum: 9.1 (mxtabs)Minimum: 9.1 (mxtabs) Maximum: 12 (msn)Maximum: 12 (msn)

What about navigation?What about navigation?

No navigation aids: 5 (NBA)No navigation aids: 5 (NBA)

Text Headings: 35 (msn)Text Headings: 35 (msn)

Linked Navigation: 8 (CHUM)Linked Navigation: 8 (CHUM)

What about linking out?What about linking out?

25 sites have self-contained privacy25 sites have self-contained privacy policiespolicies

1 links to other pages on the site1 links to other pages on the site(miniclip)(miniclip)

24 are on a single page24 are on a single page(neopets)(neopets)

23 sites require linking out for complete23 sites require linking out for complete privacy informationprivacy information

(ebaumsworld)(ebaumsworld)

Privacy policies on kids’ favourite Privacy policies on kids’ favourite sites are…sites are…

Not uniformly easy to findNot uniformly easy to find

LongLong

Written at a high reading levelWritten at a high reading level

Difficult to navigateDifficult to navigate

Do you read privacy policies on the sites you visit?

Always - 5%

Sometimes -44%

Never - 51%

If a web site has a privacy policy, you can be sure they will not share any personal

information they collect from you with others.

47 42 40 36 34

53 59 60 64 67

0%

100%

Grade 7 8 9 10 11

False

True

Percent

On the websites kids visit, On the websites kids visit,

finding out about privacy is relatively finding out about privacy is relatively difficult…difficult…

BUT BUT

Disclosing personal information is NOTDisclosing personal information is NOT

Disclosure is…Disclosure is…

EasyEasy

UbiquitousUbiquitous

FunFun

SeamlessSeamless

Tied to kids developmental needsTied to kids developmental needs

The good news…The good news…

The sites kids visit usually have privacyThe sites kids visit usually have privacy

policiespolicies

The bad newsThe bad news

Policies are not easy to findPolicies are not easy to find

Once found, many policies are long, andOnce found, many policies are long, and

written at a level too difficult for childrenwritten at a level too difficult for children

and many adultsand many adults

Many policies are difficult to navigateMany policies are difficult to navigate

Many policies are not self-contained Many policies are not self-contained

The worst newsThe worst news

In contrast, disclosure of information isIn contrast, disclosure of information is

made easy, fun, and naturalmade easy, fun, and natural

We need a new approachWe need a new approach

To ensure that privacy policies are readTo ensure that privacy policies are read

To ensure that privacy policies areTo ensure that privacy policies are

understoodunderstood

To ensure that decisions about privacyTo ensure that decisions about privacy

are directly linked to disclosureare directly linked to disclosure