BBB National Programs Unveils New Guardrails for Child-Directed Advertising & Privacy in the Metaverse
McLean, VA – October 3, 2023 – BBB National Programs’ Children’s Advertising Review Unit (CARU) today released new Guardrails for Child-Directed Advertising and Privacy in the Metaverse, developed by the BBB National Programs Metaverse Working Group, a convening of diverse well-respected global industry professionals representing toy, gaming, network, food, streaming, adtech, and mobile brands popular with children.
The Metaverse Guardrails are a set of realistic, actionable recommendations and best practices intended to help companies to:
- Develop metaverse experiences directed to children;
- Comply with existing advertising and privacy law; and
- Engage responsibly with children online.
“Tens of millions of children under age 13 are active in immersive, virtual environments and game spaces, and while children can benefit from such hands-on experiences, they are also subject to unique potential risks and harms,” said Rukiya Bonner, Director, Children’s Advertising Review Unit, BBB National Programs. “The Metaverse Guardrails do not intend to resolve or respond to all the complex scenarios within the metaverse, but instead focus on providing companies with a thorough understanding of the current advertising and privacy regulatory landscape and best practices for the application of those regulations to certain scenarios in this emerging marketplace.”
Consistent with the recommendations contained in the recently released FTC staff report, Protecting Kids from Stealth Advertising in Kids Media, the Metaverse Guardrails caution advertisers not to present advertising in a manner that blurs the distinction between advertising and non-advertising content and to clearly and conspicuously disclose when something is advertising or contains advertising in a manner that children will notice and understand.
The Metaverse Guardrails encompass best practices and recommendations for how to be compliant in metaverse spaces:
- Be transparent. All advertising should be easily recognizable as advertising.
- Understand when content becomes advertising and also what is not advertising.
- Know when, how, and how often to properly disclose your advertising, including influencers and endorsements.
- Protect children’s privacy. Get to know COPPA, the Children’s Online Privacy Protection Act.
- Be aware of relevant state-level and international privacy regulations.
"In the evolving metaverse space there is a real need for brands to tread cautiously, especially when it comes to safeguarding children,” said Dona Fraser, Senior Vice President, Privacy Initiatives, BBB National Programs. “Recognizing that this space presents a novel landscape for advertising and privacy concerns, it's imperative for businesses to consider all its complexities and nuances to ensure a safe and transparent digital environment for young users."
BBB National Programs’ CARU monitors child-directed media to ensure compliance with CARU’s Advertising & Privacy Guidelines, widely recognized industry standards to assure that advertising directed to children is not deceptive, unfair, or inappropriate for its intended audience and, in an online environment, children’s data is collected and handled responsibly. CARU seeks the voluntary cooperation of companies and, where necessary, refers companies to an appropriate federal or state regulatory body, usually the Federal Trade Commission (FTC) or state Attorneys General, for legal enforcement action.
In August 2022, as a precursor to these Guardrails, CARU issued a compliance warning, putting advertisers, brands, influencers and endorsers, developers, and others on notice that CARU’s Guidelines apply to the metaverse and that CARU will strictly enforce its Guidelines.
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