BBB National Programs Archive

CARU Recommends HD Group Modify Website to Better Protect Children’s Privacy; Company Implements Recommendations

New York, NY – Feb. 13, 2013 – The Children’s Advertising Review Unit recommended HD Group, LLC, modify the website to better protect children’s privacy. The company has done so.

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 the federal Children’s Online Privacy Protection Act (COPPA).

The website is a social networking site for teens and tween girls, offering them the ability to communicate online with each other about fashion, current events, celebrities, and other trending topics. Members can create their own profiles and comment on other members’ walls. There are also games, activities, and contests.

Upon its initial review, CARU noted that the site’s home page featured a link to “Tell a Friend,” about the website (and that it was possible to tell multiple friends at once). To do so, visitors were required to enter an email address and the email addresses of friends. The email received by the friend displayed the member’s email address. There were also multiple opportunities on the website to “Tell a Friend” about certain activities such as dress up games, high scores, art work, etc.

Following its initial review, CARU questioned whether the website was in compliance with its guidelines and COPPA. CARU was concerned with the following practices:

• Children under 13 are able to enter PII on the profile page without their parent’s consent.
• The Operator’s method of obtaining parental consent for the Level 2 membership does not comply with the Guidelines and COPPA.
• When a child uses the “Tell a Friend” function, her email address appears in the recipient’s inbox.
• The Website links to Twitter, a social networking that is not intended for use by children.

Following CARU’s inquiry, the website operator:

• Eliminated the ability to share PII on the profile page, and anywhere else on the website without verifiable parental consent.
• Amended its parental consent procedures and implemented a new means of verifying parental consent.
• Modified its “Tell a Friend” practices to assure that the sender’s email address is not visible.
• Eliminated the links to Twitter.

CARU noted in its decision that it appreciated the operator’s cooperation.