BBB National Programs Archive

CARU Recommends Modify Website to Better Comply with Guidelines, COPPA

New York, NY – Feb. 9, 2016 – Rachel Renée Russell, author and operator of the website, said the site has revised its privacy practices following an inquiry from the Children’s Advertising Review Unit.

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 advertising to children in all media. CARU also examines websites and apps for compliance with CARU’s Self-Regulatory Program for Children’s Advertising – which includes guidelines on online privacy protection – as well as with the federal Children’s Online Privacy Protection Act (COPPA).

CARU was directed to the website through an advertisement in Discovery Girls magazine, which read: “Read Nikki’s blog, get advice, and more at”

At the website, teachers, teens and tweens learn about the book series, Dork Diaries, and its author, Ms. Russell.  The website featured an area labeled fan club, an e-newsletter, advice column, games and merchandise.

Upon its initial review, CARU determined that to sign up for the fan club, a visitor had to enter an email address, first name, month and day of birth, and a parent’s email address.

Underneath were two check boxes.  The first stated, “I confirm that I am over 13 years old.”

The second stated, “I confirm that I have asked my parent/guardian to read this notice.  If you are a parent/guardian of the entrant and you consent to the retention and use of the entrant’s personal details for the purposes of these newsletters, please click this box.”

With regards to the website’s e-newsletter, a visitor was asked to enter a username, password, email address, first name and a full date of birth.  Below were the same check boxes and messages that appeared in the fan club section.  This feature did not request a parent’s email address, regardless of the birthdate submitted.

CARU’s guidelines provide that operators should ask screening questions in a neutral manner so as to discourage inaccurate answers from children trying to avoid parental permission requirements.

In response to CARU’s inquiry, the operator indicated she would modify the site to comply with CARU’s guidelines and COPPA. The operator explained that the fan club had the same function as the e-newsletter subscription and that parent notification letters were being sent out manually and were often delayed.

The operator also informed CARU that she has removed the fan club sign-up from the website to avoid confusion with the e-newsletter feature.

CARU noted in its decision that it was pleased the site operator “had agreed to participate in CARU’s self-regulatory program  and implement changes to bring the Website’s privacy and advertising practices into compliance  with its guidelines and COPPA.

CARU noted in its decision that the operator has updated the site’s age-verification system to effectively age-screen and send out a parent notification for the Dork Diaries Superfan e-newsletter in a timely manner.  The operator expressed her thanks to CARU and said the site “has already been modified to fully comply with the CARU Guidelines and COPPA.”