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Two teenage boys use their smartphones as they sit on a bench in Vail, Colorado.

Two teenage boys use their smartphones as they sit on a bench in Vail, Colorado. (Photo: Robert Alexander/Getty Images)

Advocates Petition FTC to Set Rules Against 'Manipulation' of Kids Online

"The manipulative tactics described in this petition that are deployed by social media platforms and apps popular with kids and teens are not only harmful to young people's development—they're unlawful."

Kenny Stancil

A coalition of health and privacy advocates filed a petition Thursday asking the U.S. Federal Trade Commission to create rules barring social media platforms and app developers from intentionally deceiving children and teens into spending more and more hours on the internet, where their sensitive data is sold to profit-seeking advertisers.

"The hyper-personalized, data-driven advertising business model has hijacked our children's lives."

"When minors go online, they are bombarded by widespread design features that have been carefully crafted and refined for the purpose of maximizing the time users spend online and activities users engage in," says the petition, drafted by the Communications and Technology Law Clinic at Georgetown University.

Led by Fairplay and the Center for Digital Democracy, 21 groups urged the FTC to "establish rules of the road to clarify when these design practices cross the line into unlawful unfairness."

According to the petition, "The vast majority of apps, games, and services that are popular among minors generate revenue primarily via advertising, and many employ sophisticated techniques to cultivate lucrative long-term relationships between minors and their brands."

In an accompanying blog post, Fairplay education manager Rachel Franz detailed some of the manipulative "user-engagement tactics" that TikTok, Twitter, YouTube, Facebook, Instagram, Snapchat, and other corporations use to ensnare young people on the web and undermine their well-being.

Common techniques include autoplay, endless scroll, and strategically timed advertisements, as described below.

User-engagement tactics that manipulate kids (Source: Fairplay)

"It's hard for kids to put down their digital devices—and that's exactly what the tech companies want," wrote Franz. "And, currently, there is no rule that says that tech companies can't use these design practices on our kids, despite the countless harms they cause."

"We know that excessive time online displaces sleep and physical activity, harming minors' physical and mental health, growth, and academic performance," she continued. "Features designed to maximize engagement also expose minors to potential predators and online bullies and age-inappropriate content, harm minors' self-esteem, and aggravate risks of disordered eating and suicidality. The manipulative tactics also undermine children's and teens' privacy by encouraging the disclosure of massive amounts of sensitive user data."

Franz added that "now is the time for the FTC to declare that these practices are unfair."

The new petition comes just months after California enacted its Age Appropriate Design Code—a law requiring digital platforms to "prioritize the privacy, safety, and well-being of children" over profits—and as pressure grows for the U.S. Congress to pass the Kids Online Safety Act and the Children and Teens' Online Privacy Protection Act.

"The manipulative tactics described in this petition that are deployed by social media platforms and apps popular with kids and teens are not only harmful to young people's development—they're unlawful," Fairplay policy counsel Haley Hinkle said in a statement. "The FTC should exercise its authority to prohibit these unfair practices and send Big Tech a message that manipulating minors into handing over their time and data is not acceptable."

For Katharina Kopp, deputy director of the Center for Digital Democracy, "The hyper-personalized, data-driven advertising business model has hijacked our children's lives."

Echoing others, Kopp noted that "the design features of social media and games have been purposefully engineered to keep young people online longer and satisfy advertisers." She urged the FTC to "adopt safeguards that ensure platforms and publishers design their online content so that it places the well-being of young people ahead of the interests of marketers."

Dr. Jenny Radesky, associate professor of pediatrics at the University of Michigan and chair-elect of the American Academy of Pediatrics Council on Communications and Media, said that "as a pediatrician, helping parents and teens navigate the increasingly complex digital landscape in a healthy way has become a core aspect of my work."

"If the digital environment is designed in a way that supports children's healthy relationships with media, then it will be much easier for families to create boundaries that support children's sleep, friendships, and safe exploration," said Radesky. "However, this petition highlights how many platforms and games are designed in ways that actually do the opposite: They encourage prolonged time on devices, more social comparisons, and more monetization of attention."

"Kids and teens are telling us that these types of designs actually make their experiences with platforms and apps worse, not better," she added. "So we are asking federal regulators to help put safeguards in place to protect against the manipulation of children's behavior and to instead prioritize their developmental needs."


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