New York, NY – Nov. 20,  2014  – The Children’s Advertising Review Unit has recommended that Boys Scouts of America modify its website, Boyslife.org, to assure that information collection practices are in compliance with CARU guidelines and the Children’s Online Privacy Protection Act (COPPA).

CARU is an investigative unit of the advertising industry’s system of self-regulation.  It is administered by the Council of Better Business Bureaus. CARU monitors websites for compliance with CARU’s Self-Regulatory Program for Children’s Advertising including guidelines on Online Privacy Protection, as well as with COPPA.

In this case, CARU was directed to the website by an advertisement in BSA’s “Boy’s Life” magazine.  The advertisement promoted a photo contest entitled, 2014 Boy’s Life Summer Fun Photo Contest.

The advertisement stated: “Take photos of anything from your summer – people, places, Scout outings or camp, whatever.  Just make sure you show summer fun!”

When CARU reviewed the website, it observed that the contest entry form collected the age of the visitor (either 6-11 or 12-17).  If a visitor chose the 6-11 age range, he could enter a photo of himself into the contest as well as type a description of the photo that included personally identifiable information.

The entry form noted that “online contact information would be collected from entrants for the sole purpose of a one-time response to contact the contest winner.”

CARU was concerned that the website collected Personally Identifiable Information (PII) in the form of a child’s online contact information, a photo and a description of the photo that included PII without first obtaining parental consent.

BSA explained that it thought that its collection of PII in its contest fell under the COPPA one-time exception to prior parental consent but that it would work with CARU to bring its contest into compliance with COPPA and the guidelines.

CARU noted in its decision that the one-time exception rule applies only to the collection of a child’s online contact information.   In this case, the website also collected a photo of a child and allowed a child to submit an accompanying caption that could contain PII.

BSA said that it accepted “CARU’s decision and is appreciative of the guidance offered in modifying our contest entry pages and rules. The Boys’ Life contest engine will undergo a complete legal review to ensure future compliance with COPPA and CARU’s Guidelines.”