Children's Advertising Review Unit - Advertising to Children

Children’s Advertising Review Unit

The Children’s Advertising Review Unit (CARU), the nation’s first Safe Harbor Program under the Children’s Online Privacy Protection Act (COPPA), helps companies comply with laws and guidelines that protect children under age 13 from deceptive or inappropriate advertising and ensure that, in an online environment, children's data is collected and handled responsibly. When advertising or data collection practices are misleading, inappropriate, or inconsistent with laws and guidelines, CARU seeks change through the voluntary cooperation of companies and where relevant, enforcement action.

Program Impact

CARU was established in 1974 to support self-regulation in the advertising industry and promote responsible advertising to children. The results of CARU’s work is available to the public.

 

 

Monitoring and Enforcement

CARU monitors child-directed media to ensure that advertising is truthful, accurate, appropriate, and compliant with its self-regulatory guidelines, and that online marketing is compliant with both the CARU guidelines and the Children’s Online Privacy Protection Act (“COPPA”).

Pre-Screening Service

From concept to final cut, CARU’s pre-screening services help businesses and agencies spot and correct problems before ads and promotional websites go live. Take advantage of our one-on-one support as you navigate COPPA and CARU compliance.

COPPA Safe Harbor Services

CARU is the first FTC-approved Safe Harbor Program under the Children’s Online Privacy Protection Act (COPPA) and can help your company achieve its business goals while ensuring compliance with COPPA requirements, other applicable online data privacy laws, and CARU’s guidelines.

Guidelines & Procedures


CARU leads the development and ongoing management of advertising guidelines for children under age 13. To help businesses and advertisers, CARU provides education, one-on-one support, and legal guidance on: 

 

  • How to be compliant in the delivery of everything from digital ads to product packaging
  • The art of delivering for an impressionable and vulnerable child audience
  • Children’s privacy, unique to digital content and data collection for children under age 13 (these guidelines reflect changes in COPPA)
  • How to approach product presentations, appropriate disclosures, sweepstakes and contests, safety, endorsements, and sales pressure

News & Blog

BBB National Programs’ Children’s Advertising Review Unit Urges FTC to “Follow Up Now” on U.S. Senators’ Call for Inquiry into the State of Children’s Privacy

Leader of nation’s first COPPA Safe Harbor wants “fast action, but not at expense of COPPA Rule Review”  

New York, NY, May 11, 2020 – With widespread recognition that the COVID-19 pandemic has elevated children’s risk online, BBB National Programs’ Vice President Dona Fraser, who leads the non-profit organization’s Children’s Advertising Review Unit (CARU), today issued the following statement in support of a call by a bipartisan group of U.S. Senators that the Federal Trade Commission (FTC) conduct an inquiry into the state of children’s privacy in digital advertising and educational technology: 

“The millions of children in quarantine due to the novel coronavirus outbreak are increasingly relying on technology for education and entertainment, and with that greater reliance comes the need for corporate responsibility. Now that this bipartisan group of U.S. Senators has demanded that education technology companies practice such responsibility, the FTC should follow up on that request. Among the questions that the FTC should pose for ‘ed tech’ companies to answer are: 

  • How are you making your privacy practices known? 
  • What is your data retention policy?   
  • If your company is collecting personally identifiable information from children, are you separating that data from the data collected about adults (or persons 13 or over)? How are those databases secured and who has access?
  • How are you monitoring what third parties do with the data they touch or collect on your behalf? 

 

There is no doubt that the pandemic has put a spotlight on the ed tech space as never before and the Senators’ letter puts ed tech companies on notice. We encourage fast action by the FTC, but not at the expense of the current COPPA rule review. Specifically, I am concerned that requests for 6(b) orders might slow down or derail the work the FTC has already begun in this review, the results of which are critical to CARU’s role in monitoring companies’ child-directed advertising and data collection practices. My hope is that the Senators’ concerns will be taken into consideration while the rule review presses forward.” 

The FTC generally reviews its rules every ten years to ensure that they have kept up with changes in the marketplace, technology, and business models. The FTC fast-tracked the COPPA rule review due to the advancement of technologies since the last rule review, which was completed in 2012 and went into effect July 1, 2013. The lawmakers’  letter urged the FTC to use its authority to conduct a study and compel ed tech and digital marketing companies to provide information about their data collection and processing practices involving children. The letter was co-signed by Sens. Ed Markey (D-Mass.), Josh Hawley (R-Mo.), Richard Blumenthal (D-Conn.), Bill Cassidy (R-La.), Dick Durbin (D-Ill.) and Marsha Blackburn (R-Tenn.). 

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About the Children’s Advertising Review Unit (CARU): CARU, a division of BBB National Programs and the nation’s first Safe Harbor Program under the Children’s Online Privacy Protection Act (COPPA), helps companies comply with laws and guidelines that protect children from deceptive or inappropriate advertising and ensure that, in an online environment, children's data is collected and handled responsibly. When advertising or data collection practices are misleading, inappropriate, or inconsistent with laws and guidelines, CARU seeks change through the voluntary cooperation of companies and where relevant, enforcement action. 

About BBB National Programs: BBB National Programs is a non-profit that fosters trust, innovation, and competition in the marketplace through the development and delivery of cost-effective, third-party self-regulation, dispute resolution and other programs. BBB National Programs is where businesses turn to enhance consumers’ trust and consumers are heard. BBB National Programs is the home of leading industry self-regulatory and dispute resolution programs designed to resolve business issues and advance shared objectives by responding to marketplace concerns to create a better customer experience. To learn more about industry self-regulation, please visit: BBBNP.org


Blog

Case Study: Getting to Compliance with CARU and COPPA

In a recent case, CARU worked with TickTalk to help them achieve compliance with CARU’s Privacy Guidelines and the Children’s Online Privacy Protection Act (COPPA). CARU sat down with TickTalk once the case had closed to discuss their experience as well as some of the privacy challenges many companies face in the children’s space.
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Blog

Pursuing Best Practices For Representation In Advertising

As advertising volume increases, so too do people’s expectations of representation in advertising. Unfortunately, advertising collectively is still falling short, and consumer perceptions reflect that. Why answer this call from consumers? And what is being done about it?
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BBB National Programs provides summaries of all case decisions in the Case Decision Summary library. For the full text of National Advertising Division, National Advertising Review Board, and Children’s Advertising Review Unit decisions, subscribe to the Online Archive. For members of the press, the full text of any BBB National Programs decision is available by emailing the request to press@bbbnp.org

 

 

 

Upcoming Events

ACI's 6th Advanced Summit on Food Law – Regulation, Compliance, and Litigation

Debra Policarpo, Senior Attorney, Children’s Advertising Review Unit (CARU) and Lauren Eskenazi, Program Manager, Children's Food and Beverage Advertising Initiative (CFBAI) discuss Addressing the Uni ...
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Jul 14, 2022 Virtual

NAD 2022 Annual Conference

Register today for the National Advertising Division (NAD) annual conference, NAD 2022, which will focus on the evolving nature of the intangible contract that exists between brands and consumers. The ...
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Sep 19, 2022 Washington, DC
 

 

 

CARU Supporters

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CARU Supporters have access to benefits and resources including:

 

  • Access to CARU experts to answer your questions about advertising and privacy issues directed to children

  • Complimentary advertising pre-screening and guidance from expert staff

  • Invitation to the annual Supporters’ Council Meeting to discuss industry challenge

 

 

 

Interested in more information about becoming a CARU Supporter?  Contact our National Partners team to learn how.

 

 


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