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Privacy Policies on Kids’ Favourite Web Sites. Jacquie Burkell, University of Western Ontario Valerie Steeves, University of Ottawa. Children’s Online Privacy Protection Act. Sites directed at children Privacy policy Verifiable parental consent for children under 13 years of age. - PowerPoint PPT Presentation
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Privacy Policies on Kids’ Privacy Policies on Kids’ Favourite Web SitesFavourite Web Sites
Jacquie Burkell, University of Western OntarioJacquie Burkell, University of Western Ontario
Valerie Steeves, University of OttawaValerie Steeves, University of Ottawa
Children’s Online Privacy Children’s Online Privacy Protection ActProtection Act
Sites directed at childrenSites directed at children
Privacy policyPrivacy policy
Verifiable parental consent for children Verifiable parental consent for children
under 13 years of ageunder 13 years of age
Personal Information Protection Personal Information Protection and Electronic Documents Act and Electronic Documents Act
Consent-based information regimeConsent-based information regime
Openness about information practicesOpenness about information practices
Legal guardian can consent for minorLegal guardian can consent for minor
Is Web Use Supervised?Is Web Use Supervised?
COPPA and PIPEDA provide for andCOPPA and PIPEDA provide for and even assume parental involvement foreven assume parental involvement for consentconsent
BUT, in 2005…BUT, in 2005… only 13% of children surveyed are “mostly” only 13% of children surveyed are “mostly”
with an adult when using the Internetwith an adult when using the Internet Among the youngest respondents (grades Among the youngest respondents (grades 4-5), 73% are “sometimes” or “usually” alone 4-5), 73% are “sometimes” or “usually” alone
when they use the Internetwhen they use the Internet
Transparent Transparent Information Information Practices Practices
+ Voluntary Disclosure
= Informed consent
OverviewOverview
How accessible are privacy policies onHow accessible are privacy policies on
the sites kids visit?the sites kids visit?
How easy are they to understand?How easy are they to understand?
Kids’ Favourite SitesKids’ Favourite Sites
• 5,272 kids• 2,800 favourite sites
• Over 25% picked Neopets
• Over 25% picked Addictinggames
Kids’ Favourite SitesKids’ Favourite Sites Game sitesGame sites Multimedia/streaming sitesMultimedia/streaming sites Special interest sitesSpecial interest sites Shopping sitesShopping sites Television sitesTelevision sites
Only 1% were sites directed at children Only 1% were sites directed at children
The Top 50 SitesThe Top 50 Sites
Represent over one-half of all choicesRepresent over one-half of all choices 50 of 50 (100%) are commercial sites50 of 50 (100%) are commercial sites 45 of 50 (90%) ask kids to register45 of 50 (90%) ask kids to register 47 out of 50 (94%) collect personal47 out of 50 (94%) collect personal
informationinformation 48 out of 50 (96%) have privacy policies*48 out of 50 (96%) have privacy policies*
* As of September, 2005; one additional site has added a privacy policy since * As of September, 2005; one additional site has added a privacy policy since that datethat date
An accessible policy is …An accessible policy is …
Linked directly from the home pageLinked directly from the home page
Immediately visible on the home page Immediately visible on the home page
Emphasized to be highly visibleEmphasized to be highly visible
Clearly labeled to identify contentClearly labeled to identify content
Is there a privacy policy?Is there a privacy policy?
48 of 50 (96%) have a link to a privacy48 of 50 (96%) have a link to a privacy
policypolicy
1 site has a ‘dead link’1 site has a ‘dead link’
1 site has no link, no policy1 site has no link, no policy
How many links to the policy?How many links to the policy?
3 websites with 2 links to the policy3 websites with 2 links to the policy
45 websites with 1 link45 websites with 1 link
1 website with a link, no policy1 website with a link, no policy
Can you see it immediately?Can you see it immediately?
First page, no scrolling: 21First page, no scrolling: 21
1,2, or 3 screenlengths of scrolling: 181,2, or 3 screenlengths of scrolling: 18
More than 3 screenlengths scrolling: 9More than 3 screenlengths scrolling: 9
1 site has a link, but not on the home1 site has a link, but not on the home
pagepage
Where is the link?Where is the link?
Top: 7Top: 7 centre: 2centre: 2 right: 5right: 5
Side Navigation: 2Side Navigation: 2
Bottom: 39 Bottom: 39 centre: 29centre: 29 left: 10 left: 10
Not on home page: 1Not on home page: 1
How visible are the links?How visible are the links?
Unique, highly visible: 5Unique, highly visible: 5
Primary navigation/Key link: 3Primary navigation/Key link: 3
Secondary navigation: 16Secondary navigation: 16
Fine Print: 22Fine Print: 22
Minimized: 3Minimized: 3
How are the links labelled?How are the links labelled?
47 of the 49 links use the word ‘privacy’47 of the 49 links use the word ‘privacy’ PrivacyPrivacy Privacy policyPrivacy policy Safety and privacySafety and privacy
2 of the 49 do not2 of the 49 do not Terms and ConditionsTerms and Conditions LegalLegal
Doing it right: Doing it right: CandystandCandystand KazaaKazaa
Making it hard to find:Making it hard to find: NewgroundsNewgrounds
The rest of the picture…The rest of the picture…
Getting to the policy is only the first stepGetting to the policy is only the first step
Privacy policies must be understood byPrivacy policies must be understood by
the usersthe users
An understandable policy is…An understandable policy is…
Relatively shortRelatively short
Written at an appropriate reading levelWritten at an appropriate reading level
Easy to navigate, with appropriate sub-Easy to navigate, with appropriate sub-
headingsheadings
Self-contained (does not require linkingSelf-contained (does not require linking
out)out)
How long are the policies?How long are the policies?
Average word count: 1902Average word count: 1902 Minimum: 121Minimum: 121 Maximum: 6414Maximum: 6414
What is the reading level?What is the reading level?
Flesch Reading Level (60-70 is acceptable forFlesch Reading Level (60-70 is acceptable for adult readers, higher is better)adult readers, higher is better)
Average: 36.32Average: 36.32 Best: 58.9 (ebaumsworld)Best: 58.9 (ebaumsworld) Worst: 23.3 (flowgo)Worst: 23.3 (flowgo)
Flesch Reading Level (Grade 8 is acceptableFlesch Reading Level (Grade 8 is acceptable for adult readers)for adult readers)
Average: 11.66Average: 11.66 Minimum: 9.1 (mxtabs)Minimum: 9.1 (mxtabs) Maximum: 12 (msn)Maximum: 12 (msn)
What about navigation?What about navigation?
No navigation aids: 5 (NBA)No navigation aids: 5 (NBA)
Text Headings: 35 (msn)Text Headings: 35 (msn)
Linked Navigation: 8 (CHUM)Linked Navigation: 8 (CHUM)
What about linking out?What about linking out?
25 sites have self-contained privacy25 sites have self-contained privacy policiespolicies
1 links to other pages on the site1 links to other pages on the site(miniclip)(miniclip)
24 are on a single page24 are on a single page(neopets)(neopets)
23 sites require linking out for complete23 sites require linking out for complete privacy informationprivacy information
(ebaumsworld)(ebaumsworld)
Privacy policies on kids’ favourite Privacy policies on kids’ favourite sites are…sites are…
Not uniformly easy to findNot uniformly easy to find
LongLong
Written at a high reading levelWritten at a high reading level
Difficult to navigateDifficult to navigate
Do you read privacy policies on the sites you visit?
Always - 5%
Sometimes -44%
Never - 51%
If a web site has a privacy policy, you can be sure they will not share any personal
information they collect from you with others.
47 42 40 36 34
53 59 60 64 67
0%
100%
Grade 7 8 9 10 11
False
True
Percent
On the websites kids visit, On the websites kids visit,
finding out about privacy is relatively finding out about privacy is relatively difficult…difficult…
BUT BUT
Disclosing personal information is NOTDisclosing personal information is NOT
Disclosure is…Disclosure is…
EasyEasy
UbiquitousUbiquitous
FunFun
SeamlessSeamless
Tied to kids developmental needsTied to kids developmental needs
The good news…The good news…
The sites kids visit usually have privacyThe sites kids visit usually have privacy
policiespolicies
The bad newsThe bad news
Policies are not easy to findPolicies are not easy to find
Once found, many policies are long, andOnce found, many policies are long, and
written at a level too difficult for childrenwritten at a level too difficult for children
and many adultsand many adults
Many policies are difficult to navigateMany policies are difficult to navigate
Many policies are not self-contained Many policies are not self-contained
The worst newsThe worst news
In contrast, disclosure of information isIn contrast, disclosure of information is
made easy, fun, and naturalmade easy, fun, and natural
We need a new approachWe need a new approach
To ensure that privacy policies are readTo ensure that privacy policies are read
To ensure that privacy policies areTo ensure that privacy policies are
understoodunderstood
To ensure that decisions about privacyTo ensure that decisions about privacy
are directly linked to disclosureare directly linked to disclosure