BBB National Programs Archive

CARU Recommends Scholastic Modify “Goosebumps” Website To Better Protect Children’s Privacy; Company Agrees To Do So

New York – Jan. 28, 2011 – The Children’s Advertising Review Unit of the Council of Better Business Bureaus has recommended that Scholastic Inc., modify the Website to better protect the privacy of child visitors. The company has agreed to do so.

CARU, the children’s advertising industry’s self-regulatory forum, monitors Websites 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). 

The Website at issue came to the attention of CARU through CARU’s routing monitoring of Websites directed to children. The Website is designed to promote the “Goosebumps Horrorland” video game, rated by the Entertainment Software Rating Board (ESRB) “E 10+,” for everyone 10 and older. 

Upon CARU’s initial review, the Website featured a trailer for the video game and allowed visitors to play games such as “Vampire Village,” “Mad Labs,” and “Terrortombs.”  On the top right of the Website, visitors were invited to “Register Your Game.” When visitors scrolled across the registration line, the following text appeared: “register your game to get news, offers, discounts, and updates.”

Visitors who clicked on “Register Your Game,” were directed to a page with the message “You must be 13 years of age or older to register your product. To verify your age, please enter your date of birth below.”

Visitors who entered a date of birth corresponding to an age under 13, received a message that stated, “Sorry, we cannot accept your information.” The visitor could then change the date of birth to correspond to an age of 13 or older and move on to the registration page.  Registrants were required to submit a significant amount of personally identifiable information (PII), including a full name, mailing address, and e-mail address.

CARU questioned the inclusion of “tip-off” language, alerting potential registrants that they must be 13 in order to sign up and the absence of technology to help prevent underage children from changing their age to circumvent age-screening.

In response to CARU’s inquiry, the company noted that the registration page was intended to be the online equivalent of the physical product registration card traditionally included in product packaging, and was intended for adults only, that fewer than 500 visitors had completed the registration and that it had not used the information collected for marketing purposes or shared it with third parties.

“Scholastic accepts CARU’s decision in its entirety, and has removed the “Register Your Game” link from the website in question. As the world’s largest children’s book publisher and a global leader in providing online content for children, Scholastic shares CARU’s goals for ensuring children’s safety and privacy on the Internet, and appreciates the opportunity to participate in the self-regulatory process,” the company said.