Dear Parents: Help me help you. Help ME. Help YOU.
So, there’s a LOT of interesting conversation happening lately… or at least I think it’s interesting (lol).
- About COPPA, future plans to COPPA, adherence to COPPA, and the FTC’s role in supporting COPPA.
- Cyberbullying & Cybersex (from the small to medium to high level interactions)
- Site responsibility vs Parent responsibility.
#3 is more or less a conversation that @JoiPod (Joi Podgorny) and I continually have as we develop methods to service our sensitive, bright, clever audience, and their parents (adjectives pending context of situation).
There are TWO ways of approaching the above topics: A) As theory & Industry conversation, B) In practice & actuality.
It’s great to come together and talk about how WE – as adults, participants in youth culture online, responsible citizens, and concerned governing bodies- can build opportunities to help kids succeed. I will ALWAYS be up for that movement / discussion. 
And yet, during my tenure within this industry and all the varieties of platforms I’ve worked with – I have started to recognize a growing movement of response and expectations for responsibility.
And so, I’m going to point my bloggin’ ranty finger at this growing movement. Fair warning, I weave in and out of all sorts of open issues regarding kids online, beyond just COPPA, and often bleed many ideals together (because when you are in the market of “practice”, it’s either you can or can’t…, and that transcends what is defined in the ‘law’, and often leads to the variety of expectations and public assumptions).
Picture this:
Instead of Superman dressing himself as Clark Kent everyday (in his ongoing efforts to protect his identity), now dozens of
Clark, close your shirt... your Superman is showing!
invisible moderators frantically attend to Superman with a mission to keep his secret safe, and a dozen invisible moderation floating through the air, shielding & blocking the public’s vision of Superman (ya know… just in case he’s forgetful or makes a mistake).
COPPA is the only legislation available to protect kids – and it’s centered around identity – NOT appropriate content.
I have always believed that if you HOUSE a site, you have responsibility for maintaining the integrity and safety for that site too. That being said:
- Is individual identity/safety becoming a community responsibility more so than personal responsibility?
- Is it the community’s ultimate responsibility to stop your child from inappropriately engaging another child?
Identity is huge, and kids need to protect themselves as much as sites are expected to. With COPPA – we know that personally identifiable information CANNOT be shared without parental approval. Ok… so that’s step one, but you and I both know, that is NOT the only expectation out there, and nor sure it be.
Extreme cyberbullying often happens when real identities are exposed online (whether usernames are shared offline or real names/contact information shared online). It also exists with inappropriate language, or just simple rudeness (you’d be surprised how simple it is to bully someone with non-aggressive, non-obvious words). So, now we have to be prepared for: privacy issues, cyberbullying, and explicit attempts at communication. (I’m not complaining, mind you!)
If I (as a site operator) set up rules and tools and back-up policies… and a child STILL tests the system with work-arounds – how far down the line will sites be held responsible for rule-breakers? Best policy suggests actions to the account (suspension or ban, access loss to features, etc), and best policy suggests that sites notify, learn, and improve systems.
Cyber-education is available ACROSS the net (there’s maybe a couple hundred organizations dedicated to cyberbullying awareness on Twitter alone). Here’s my question: when does the public’s engagement with cyber-education happen? When should it happen? And why does it feel like cyber-education only receives attention when negative things happen?
Ultimately – there is a growing need for responsibility to be taken within the home – and responsibility to be explained to the child. How do we help educate and involve all the parties (like families, schools, extended families, friends, individuals) WITHOUT having to change a website’s business-model?
This has been an open conversation for a LONG time now, and it’s a rather sensitive topic as NO ADULT who loves his/her child wants to be called out for a possible issue or failure (failure being a rather strong word, my apologies).
Our industry’s endless enigma: How to involve parents who don’t have time to be involved.
Not all garbage comes in a can... It's your business to secure your CRAP 
("Check yourself before you wreck yourself" - Ice Cube)
Look – please don’t shoot the messenger here, Parents. Momma Bear has claws and Poppa Bear bites… I know that (I was a ref for toddler soccer for 2 years in college… if you have EVER been a ref or a coach – you know what I’m referring to here). I respect the amount parents have on their plate! That being said, I ask you to talk to ANYONE who deals with kids online, and you’ll get the same response… the majority of parents only involved if something negative happens (and then it’s typically an aggressive conversation of blame with the site).
My fear: Does this mean that the government has to step in and point a greater finger of responsibility to sites? Is that what will happen with the expectations of a new COPPA? States are adding new Cyberbullying rules – are those rules going to bleed into COPPA, and therefore introduce new enforcement responsibilities or expectations on sites?
I know parents need help, they can’t possibly have eyes EVERYWHERE. Most of us in the industry want parents to expect nothing but happiness and rainbows and fun and friends, etc, within our kids websites/games. Safety reassurance is almost always a part of the business model. And industry people like me? WE ARE TRYING EVERY SINGLE DAY TO PROTECT YOUR KIDS, and often succeeding. However, new slang happens by the moment, and a minxy tween exploring language/sexuality/peer competition, etc, will do what they need to in order to surpass the mandated boundaries blocking them from their goal.
The more blocks, the higher the frustration, the more determination to get a result. Such actions = more pressure on a business, and more money spent on scaling/tools, and a greater difficulty for success which affects the audience, business, and general site entertainment. Let me reiterate another way:
- The more obstacles put on a business directed to children now will result in…
- A decrease in businesses directed to children later while will result in…
- More young kids involved in 13+/adult sites that do not have “Best practices” or “Good policy” or even “COPPA”.
We know there are a GREAT amount of kids who lied about their age to join sites like Facebook, Formspring, Foursquare (with their fancy smartphones), and Twitter.
So, as COPPA gets its make-over, and as this nation of helicopter parents grows, and kids make privacy/identity mistakes or keep attempting boneheaded social interactions… how do we aim for online success for youth without building landmines & sinking traps?
Help me, help you? Help me, help you…. Seriously. Let’s tackle this together.
How about instead of "Show me the money!" we go with "Show me the united front for taking responsibility in protecting and educating kids across the net!" ...What, not catchy? Oh, Beans.
Add your thoughts at the beep… be they charged, devil’s advocate, sympathetic, or requesting more context. I’m really interested in this as an exploration conversation.
Age Gate Complications
How the Public Interprets COPPA-Prompted Age Restrictions
Most parents and youth believe that the age requirements that they encounter when signing up to various websites are equivalent to a safety warning. They interpret this limitation as: “This site is not suitable for children under the age of 13.” While this might be true, that’s not actually what the age restriction is about. Not only does COPPA fail to inform parents about the appropriateness of a particular site, but parental misinterpretations of the age restrictions mean that few are aware that this stems from an attempt to protect privacy.
While many parents do not believe that social network sites like Facebook and MySpace are suitable for young children, they often want their children to have access to other services that have age restrictions (email, instant messaging, video services, etc.). Often, parents cite that these tools enable children to connect with extended family; Skype is especially important to immigrant parents who have extended family outside of the US. Grandparents were most frequently cited as the reason why parents created accounts for their young children. Many parents will create accounts for children even before they are literate because the value of connecting children to family outweighs the age restriction. When parents encourage their children to use these services, they send a conflicting message that their kids eventually learn: ignore some age limitations but not others.
danah boyd | apophenia » How COPPA Fails Parents, Educators, Youth
I really, truly encourage you to head over to the link above and read the beginning and end (I sectioned only a portion) of Danah’s post. She’s right.
Back when I was an early blogger, I used to get frustrated with the casual nonchalance of parents who let their kids watch Youtube, then create accounts, and then post videos (ack!)… teachers/parents who friended their U13 kids on myspace and facebook and twitter (blergh). There are a lot of these conflicts-of-interest I see happening regarding the dynamic between parents & children accessing the social/entertainment world online. As the years have gone by, I’ve stopped ranting so much about these other social media sites. I just try to make sure that the wee corners of the interwebs that I touch have some sort of care, logic, appropriateness to them.
Having said that… I, fortunately & unfortunately, have the hands-on experience working with Age Gates from one stance NOT mentioned in Danah’s post…. youth-targeted sites.
Age gates = have been a battle for many a kids biz. Frustration points I’ve encountered, or had others relay to me:
1. Most kids, teens, adults, parents don’t even bother putting in the right info – they just choose the easiest option (either the pre-populated date or January 1, 2011) from the scroll gate option. > Now they’re caught in the filter.
2. The session cookies. Yes, I think on many levels a session cookie is necessary (why would you have a gate if they can cheat the gate?). However, as mentioned by Danah, and my point 1 above – parents / adults either put in the easiest information OR they put in their CHILD’S information… > Now they’re caught in the filter and frustrated (CS ticket if you’re lucky).
3. How do you determine a child from an adult when receiving a poorly spelled (btw, yes, many parents do not spend time editting and their emails often look like a child’s – identities have been tested and proven via phone conversations, arrrg!) CS ticket regarding the age gate? Fun times. > Now they’re caught in the filter. Cookie sessioned. And possibly a poorly educated parent looking for a bit of help for their kid.
4. TIP OFF LANGUAGE – Due to the FTC & Safe Harbor Co’s attempts at trying to keep some sort of legitimate gate-action happening… This is frustrating to navigate. I agree with the need for non-tip-off language, however, this can get really questionable fast when you really start to analyze the language you’re using to explain how to use the age gate without explaining how to defeat the age gate. > Now they are caught in the age gate, cookie sessioned out, confused by why, with CS tickets submitted and no where to go…
5. Every biz wants kids to enter the lists for their closed Beta… but you can’t have a minor agree to the legal documents associated to a Closed Beta session. Ruh roh, age gates doing what they’re supposed to do against the need for the site… > Rock, meet hard place. Also, add in: Caught in the age gate, cookie sessioned out, confused by why, with CS tickets submitted, no where to go, and now questioning the legitimacy of a kids site that won’t let kids in…
Ruh Roh + Fail whale? Or age gate success? Tre sigh.
I’m not going to give you my solutions to these frustrations, but having pointed them out, hopefully you’ll understand some of the yellow flags out there regarding Age Gates. Every little heads-up helps, yeah? I hope so.
Now go read Danah Boyd. She’s much more eloquent than I am today…
Engage! Expo Conference Prezzie
Hello, hello. Long time no talk. Yes, I realize this, and I send my apologies.
Last week (Sept 22nd), I spoke at the Engage! Expo conference in Santa Clara on User Engagement – aka, the art of engaging users (specifically online gamers 13 and younger, although you could argue for a General rating). It wasn’t one of my most stellar performances, I drown a bit in having FAR too much to say… but I successfully rambled a few decent points & tales, and hopefully shared some new understandings as well.
I am always grateful to the Engage! Expo team (Tonda you’re amazing), and it was great meeting some new people.
Now, prepare yourself for some Heavy. Duty. Slide. Action. I Powerpointed it up HARD CORE (my speech teacher would be throwing ninja stars at me if he knew). Luckily, many people have contacted me asking for my Powerpoint slides… so, I am providing a video of them here.
Questions, comments, problems, scenarios, rambles, quips, complaints, queries, and soliloquies should be directed to the comment section of this post. I’ll do my best to get back to you.
Things I’m kickin’ myself for leaving out: Monetization and the “velvet rope”, How to use live staff well, the Parental Unit, and The fine art of event planning and support. Thank god there’s always future conferences – I can do a “Part Two” slide set
Is there such thing as 100% Safe Chat for kids?
My oh my, ain’t this the question of the hour. I’m definitely not going to win any friends from some people on this one, but folks – I’m not going to B.S. you here. There are people who philosophize laws and legislation based on all sorts of elements, there are people who make tools, there are people who are charged with helping, there are people who research theories, there are people who spend efforts for education or overzealous protection, there are people who have propoganda & agendas (good-good, bad-good, good-bad, bad-bad), and then there are the people who just gotta get the job done: every. single. day.
There are a lot of people in the pot trying to decide what “safety” means these days – especially regarding chat. I’m just gonna tell you a bit of insight from my side, the “every. single. day” perspective – think of it as the stage manager telling you what’s happening behind the curtain, but also knowing what is expected to be seen by those in front of the curtain. It’s a very different view from the director, or set designer, or critic, or actor, or audience…
Here are a bunch of questions I get:
1. What are the safeguards for chat for kids? (aka, what are “filters”)
As we know (or as you’re now learning), registration processes aren’t the only method of PII collection (PII: personally identifiable information – which is prohibited from being shared by children under the age of 13 through the legislation called COPPA). In these virtual experiences like MMOs and Virtual Worlds and Chat Clients and Social Networks – there are a thousand ways to share information. People put in “filters” that are trained to catch or allow content, based on the type of filter it is, so that content can or cannot appear within a social space…
- Dictionary Phrase list – basically a list of predetermined statements with no room for alteration
Pro: Your users cannot alter or break any of your systems, unless they’ve figured some alterations ultra-serious language using codes of first initials to sentences, lol
Con: Really, really, really frustrating. Really frustrating. Not a great user experience because everything is dictated, and unless it’s a GINORMOUS list of pre-determined statements, there is little room for off-the-cuff roleplay, and being dictated to is never something a pre-teen/tween child likes… - Dictionary lists – basically a list of all permitted words – like an uber list straight from the dictionary (lol – hence the clever name)
- Pro: You’re only allowing certain words and blocking out any phonetic work arounds or garbled attempts of spelling (ex: words like funkyou or asstronaut are not in the dictionary and therefore caught in the filter before appearing live).
- Con: Dictionary lists are HUGE. Let me repeat HUGE. You better scan through them for medical terms like “pubic” or “pedophilia” both of which are in the dictionary, as are “address” and “phone” and “email”. Also – phrases are not in the dictionary – such as “as hole” or “read hard dead” or “name at yahoo dot com” and “my house is on third street maytown illinios”. Heck, you can even use work arounds like “my digits are ate hero hero tree tree fort hive sicks mine on” (that says 800-334-5691 which is a number i just made up using the types of easy work arounds KIDS USE EVERY SINGLE DAY – no. joke. All words in the dictionary). Also – with every user who creates a new username – there is yet another addition to your white list. Kids have to be able to speak to each other, right? 1,000,000 users = 1,000,000 additions to the dictionary… YOUR CHAT PROGRAM IS GOING TO BE VERY, VERY SLOW. - White list – An extensive list of appropriate words (and some phrases) that your team has specifically allowed in chat (much like the dictionary chat). Typically, must have a smaller blacklist to balance out some of the issues.
- Pro: You’re starting with a set list of approved words and statements, you have a little more control over the types of conversations you wish your users to have.
- Con: Young users with issues spelling will never get to say what they’re trying to say unless you have the foresight or capability to see what they’re attempting to say and add to the white list. You have a smaller range of free community unless you’re actively keeping up with the chat of kids and making new allowances, etc. Also – good luck with symbols, characters, punctuation, and numbers – since your system has already chosen the words it likes, kids can use these other things to break what you’ve set up. Youre mini black list better be prepared for statements like “silky fingers” or “hard purple staff” or “up your skirt” or “chocolate kid” or “lets have sax” - Black List – An extensive list of inappropriate words/phrases blocked from chat, with a subsequent white list that helps balance out the black list for appropriate content.
- Pro: It’s an active list that is monitored, changed, and edited by the day to support the growing needs and cleverness of youth & pop culture in general (which can also be considered a con, lol). You know exactly what they cannot say, and removing all negative content is the emphasis while trying to be clever enough to not break the user experience (as we know, inappropriate content changes by the day – thank you South Park and Family Guy). Urbandictionary.com is a great help. You can prepare the blacklist to look for such phrases as “my addy is” or “real name” or “in your pants”)
- Con: Unless you have a tool set that can separate words, find gem-of-words within bigger cluster-words, ignore run-on vowels or extra characters, read thru spaces and numbers and symbols, etc, well… you’re going to have problems (and there ARE tools out there that do this… you just have to look, test, research, etc). This is what I call “control over your active road map” – you need to be working to verify that all options around and through your blacklist controls are sticking tight. Example: the word “ass” is inappropriate, but can be said in “class” and “assembly”… make sure it’s not caught. On the flip side, the work “retard” is never appropriate in any variation – so the filter needs to be able to catch “uretard” or “retardation” or “ret@rd” or “r3t@rd” or “mrretardkid” < all of which I’ve seen kids attempt. Also – this is not something just anyone can pick up… knowing how to work and manage a black list effectively is a solid job and needs care & cleverness.
2. Can I be 100% certain my chat system is safe from PII collection or sharing by children?
NO. Not unless everything is pre-screened before going live (example: the phrase dictionary or canned chat alternatives). And even if you had moderators screening all content before it goes live – that is a heavy scaling issue, with a lot of room for human error.
I’ve already mentioned the types of identifiable location words that need to be removed in Dictionary Chat / White list / Black list. But what I haven’t mentioned are first name / last names. Unless you restrict first names completely (including a user’s avatar name), you’re already in the hole. Why? I don’t know about you – but just because someone once told me not to date guys with two first names doesn’t mean they don’t exist (teasing about the two first names… clearly that’s just a myth… hehehe). Ryan Edwards. Tiffany Addam. Joe Gail. Larry Drake. Then you have the first name + object last name, such as Jack Hall, Charlie Brown, Jerry Trainer, Sally Stir. There’s not a chat list in the world that’s going to block that unless it’s prescripted.
On the flip side, you also have numbers (should always be removed from even TYPING a number on a keyboard – why give what they can’t even have?), symbols should be removed (there is no need for @ or > – smilies are what emotes are for), and really the only punctuation should be the exclamation point and the question mark. Even THEN you’re going to see abuse for PII sakes… “My digits are ! !!!!!!!! nil nil !!!! !!!!! !!!!! ! !! !!!! !!!!!” and there’s an 800 phone number. Or the progression in chat for this:
“my digits are after the a. write em down. A!!!!!!!!” “A nil a nill” “A!!!!” “A!!!!!” “A!” “A!!!!” “A!!!” “A!!!!!!!!!!” Again, prescripted might help stop this.
Now… here’s the thing about prescripted agendas. YOU LIMIT A KID IN A WORLD WHERE THEY’RE EXPECTED TO FORM A COMMUNITY – AND THEY’RE NOT GOING TO STICK AROUND. Sure, if the game is fun, they’ll play the game, maybe stick around for a session or two… but why even make it a social game? YOU CAN’T BE SOCIAL IF YOU CAN’T BE SOCIAL. And, heck, kids are just going to fire up their aim and/or gchat and/or msn and/or text messages. At least with the filters and time/effort you were putting it… you were doing YOUR job in trying to protect them. Put massive restrictions on chat and lose the social experience for users to some other techniques that are less capable / less responsible to do the job YOU could be doing the right way.
Which leads me back to – WHY MAKE A SOCIAL EXPERIENCE GAME? I’ve only seen Poptropica.com do this well – and they’re not really going for a social community. They’re going for game-based/story-based interactive, educational fun without community or self-expression or role play… it’s about the agenda decided for the purpose of the game.
But how do we protect / stop users from these simple methods of info sharing – like first name + last name? Put it in your rules, your Terms of Service. Inform the users, and the parents, that there could be a chance that something is shared by accident… and that your site will remove any/every user who breaks this rule. Put forth the best effort with filters and POST MODERATION (various ad hoc methods that illuminate users who are breaking the policies you’ve set). If they can’t play by the rules and regulations you’ve set, and if a user is putting your brand/game at risk… SO LONG, GOOD RIDDANCE.
The only way we can REALLY attack this problem is through education. Either in-game, pre-game, parental education & guidance… but for me, I’d like to see POP CULTURE EDUCATION. Ad campaigns, commercials, etc.
And by the way… these are only a *few* of the examples there are in work-arounds. There are MANY, MANY more, and they change, grow, mutate by the day.
3. What is the safety method of chat filtration?
The safest method is whatever you know works the best for YOU. There’s no “one” perfect situation for every company, every philosophy, every policy. Look at what your variables are:
- Who is your target user (and what might he/she say around the lunch table with friends), who is your secondary target, and who is going to show up unwanted at the party…
- What is the type of content/genre/fantasy you’re building, and how will the language that corresponds with that effect or change the typical every day language scene (example: if you have a world where everyone is an ice cream flavor – being called vanilla kid or chocolate kid doesn’t have the same context as it does in an athletic world where kids are sassing each other)
- Who is in charge of policing your policy in your world – do they understand the type of content that needs to be caught?
- Do you/your team have a sufficient enough understanding of language / pop culture / kid behaviors / online minxiness to be able to properly control / handle what you want for your audience?
- Do you want to control your language road map – or do you wish for the aid of another company to control the language?
- Do you understand what legally CANNOT be shared in chat? Do you feel you have sufficiently restricted the public sharing of PII?
- How do you want filtration to appear to the end-user?
- Do you want them to be warned for certain language?
- Do you want to put certain words in black boxes, where only the author can see it and the rest of the social room cannot?
- Do you even want kids to know what words they can/cannot say? - How are you going to know when kids are creating language work-arounds?
- If you allow a vendor to control your language lists, who carries the responsibility/burden if the list is not sufficient? (are you QA-ing your own policies / site?)
- How are you going to react to users who are breaking your policies regarding chat?
- Have you removed / scrubbed any content accidentally provided by users?
I have what works for me, and for now I’m very happy with my method. Naturally – I am always looking / learning / finding new ways of improvement for policy, implementation, experience, etc. That’s my job. At the end of the day, I am accountable for the users and the company. Not only is there legislation, there is a sensitive and young audience involved.
This all leads to the “what next” step of COPPA and the recent COPPA round table that happened at the start of June. To be honest – I’m scared. I’m scared because there are a lot of different ideologies floating around regarding PII and chat. The fact conversations are happening isn’t what scare me – it’s the lack of hands-on knowledge from people who have to do this every day (and I’m not talking about the directors or managers who haven’t even once signed into their tool set – trust me, there are a few of those out there).
There seems to be a lot of people looking at what’s working for others and trying to do the same… but no two sites, no two games, no two companies work the same. Chat always seems to be one of the LAST thoughts for people… not that it needs to exist – but HOW, and what the experience is like for the end-user. Font, character allowance, timing, content – it’s essential and standard and needs to be treated in design and creation with the same respect as EVERYTHING important to the agenda of the site.
I’d like to see more people close their doors, Willa Wonka style, and figure it out for themselves – so they can speak to it and cop to it, etc. I, for one, should not know your chat filter holes better than you do….
Let’s Chat: COPPA
Twitter. I promised a rant on twitter. I promised a rant due on Thurs. It’s Sunday.
My apologies for the lateness and the possible lack of DRAGON FIRE that I was spittin’ on Thursday. Indeed I was angry, and it had to do with weird (if not troubling and disappointing) rumors spread about COPPA. But like the fear-mongering such rumors create – a tantrum is not what is needed here either. Clarity is what is needed.
So, my dear poppets – lemme share the facts about COPPA: Past, Present, and Future…
PAST
COPPA is the only “real” legislation we have to enforce/protect children under the age of 13. COPPA stands for: Children’s Online Privacy Protection Act. It was created to stop marketers from collecting and exploiting personally identifiable information from children. What is personally identifiable information (or PII)?
First name / last name, phone number, email address, social security number, home address.
It’s also to good to consider the following PII:
School name, instant message clients, usernames for other sites, sister/brother/parents/teacher full names, zip code, small town + states, after school activity locations. – These are not held as stringently as the first group, but they’re equally as important since you can locate any child regarding this information. Basically: if I can find you easily with the info you provide… that could be argued as PII.
Remember this tip for the kiddies and yourself: Tangible/Open Air (non computer) life = Clark Kent, Online life = Superman.
COPPA is upheld by the FTC, who regularly posts announcements on their page: http://www.ftc.gov/. There is a program governed by the FTC called “Safe Harbor”, and it is upheld by four organizations (CARU, ESRB, TRUSTe, Privo). If you wish to be a part of the Safe Harbor program – you will get aid in meeting regulations, suggestions for “going beyond” and being better than bare minimum, and you will have legal representation if your compliance comes into question. I have had the privilege to work with CARU and the ESRB (whom I am very happy to work with now), and I know the fine folks at Privo. I would definitely suggest that any company or individual wishing to learn more about Safe Harbor reach out to these companies.
At one point they tried to make additional legislation: COPA (Children’s Online Protection Act) and DOPA (Deleting Online Predators Act) – both of which have been dismissed due to First Amendment (COPA) and sheer impossibility due to variables (the latter).
PRESENT
How is COPPA being used? Well, no longer just a deterrent for Marketers, it is the sole legislation for anyone collecting any information regarding children under 13. But why would someone need to collect info from kids?
1. Newsletters
2. Registration for games
3. submitted in conversation (chat), pictures, audio, etc (basically – UGC, “User Generated Content”)
I exist in the epicenter of business, safety, entertainment, common sense, community, and I’m telling you… there is no real arguable reason to collect PII from children. The decision regarding the sharing of any such PII information belongs to the parents. Ahh, now there’s the rub – how do parents make/enact/provide/receive that permission?? Lemme get to that in a sec.
What I forgot to mention in the “Past” section is that – COPPA legislation pinpoints 4 acceptable ways to gain PERMISSION to collect PII: a fax with a parents signature, valid credit card, phone call acceptance, and email-plus. Naturally there are problems with all four methods.
- Fax = expensive, not “earth” friendly, and who really owns a fax anymore? Not to mention – kids attempt to sign and fax themselves (the wily things they are). You lose more customers than you gain when you expect them to stop at KINKOS to fax something out – too much time, so long future customer.
- Valid Credit Card = No one wants to put their digits in (and they had the 1 dollar charge, despite the fact we dismiss the charge), kids as young as 9 are toting their parent’s credit cards, it’s an opportunity to collect PII inadvertently from a child (AGE GATE MEMBERSHIP, pls), and kids have been known to take the card from mom’s purse (the cheeky things they are). Strangely enough – for parents who do not have any intention on purchasing a membership – they don’t really want to put in any CC information. Do I blame them? Nope. Too many “but what if my kid can access my number” or “But I don’t want to tricked into paying” or “Ugh, I have stuff to do. Dinner is almost ready. I don’t want to do this now, let’s go eat.” deterrent!
- Phone Call Acceptance = Heavy lifting on the part of CS, expensive call services, and how do you determine an adult’s voice if the adult happens to be squeaky? Or a child who has low tones? And, kids attempt to call in pretending to be parents (the sneaky things the are). One of the easier methods “in theory” – parents can just pick up and dial and say “yes” or whatever. No biggie. Except that – parents can’t make those phone calls if they’re at work, and sadly, from what I’ve heard, more kids call in than actual parents.
- Email Plus = The least rigid, most used, least reliable method. You request the parent’s email during the kid registration, you send a “Welcome” email that includes a click-through link that will open up UGC possibilities, the adult visits the link and chooses to allow or not allow UGC, and 24 hours later the parent gets another email reminding them that they did this (in case kids invade the family email, they will be caught “unawares” by the follow-up – or at least that’s the theory). The problem is that – a certain percentage of kids are putting their own email into the Parent Email slot, and trump the whole parent connection.
Personally, I lean towards Email Plus as a method these days. As I said – I’m in the epicenter of a lot of needs. My first and foremost goal is: SAFETY, followed by ENTERTAINMENT (kid style), and then the business, etc. Granted Email Plus isn’t the “safest” – but that’s why I have POLICY AND PROCEDURE. I have moderation toolsets and staff, and, well me (cue chip on shoulder, my apologies). We work behind the scenes during the live existence of the game to ensure that privacy remains active, despite the audience themselves. AND TRUST – this ain’t no walk in the park.
Children DO NOT understand what they should / should not speak about, nor do they get (en masse, I’m talking about now) why they should / should not speak. So… you can pretty much guarantee that kids will attempt to share SOMETHING – the way around collecting this is:
- Pre-screening & scrubbing content,
- Filters that block anything close to PII (heavy, heavy black lists, or CLEVER dictionary chat that also reads phrases),
- Filters that jedi-mind-trick the user (have you tried chatting with another user in Club Penguin? Only like 25-30% of what you try to say actually shows up to the public – this lowers frustration from users while safety guarding them from the public),
- Scripted chat (Poptropica is still uber-popular and there isn’t an ounce of open or filtered chat
- Post-hoc moderation – LIVE 24/7 staff on the look out for kids who figured out “work arounds” (like toe tree fort hive stick stephen for two three four five six seven)
- Reporting mechanisms for kids to pinpoint those who are cheating the system
You don’t have to have all of them… but it’s a big decision to make, and not lightly either. Get council (from someone not selling you a product, please).
Once I have my front-line and behind-the-scenes methods in place – my next goal is to make sure kids come in and play the game… that they’re active and enjoying it. If I don’t have kids on my site, I have no audience: no money, no sustainability, no kids to protect, no job. And where does that leave kids? Instead of at Disney World with the families and the attention to detail and overpopulated staff, they’re at Six Flags with the gangs and high school peer pressure (seriously, have you BEEN to a Six Flags in the last ten years? What is up with that? Um, NO, I don’t want to watch fourteen year olds try to make babies while I’m in line to ride on Batman, thank you. And no, I didn’t bring my Latin Kings sweatshirt today, darn I don’t fit in).
I do not, not, not recommend “Email Plus” for who has no intention of truly backin’ up the LIVE safety on their site.
If you do not have valid parental sign off for your online experience: you cannot allow UGC of any kind unless it’s screened first by staff and scrubbed of possible PII. That means: usernames, chat, forum threads, forum posts, blog comments, guest books, comment walls, upload pictures, upload video, upload audio. Basically: anything a user can submit needs to go through filters and screening. Anything considered PII needs to be scrubbed.
What’s good policy? Well, even when you GET the “valid parental permission” – you still filter the content, and you still have staff moderating. This is YOUR brand and YOUR audience.
BTW: If anyone comes to you and tells you that a toolset will solve all your problems and that it will replace human staff – you better get your warning flag up. THEY’RE SELLING YOU. Gross.
THE FUTURE
So, about two months ago I had the EXTREME privilege to sit on a stage at the Engage! Expo conference in NYC with Phyllis Marcus. Phyllis is from the FTC and had been commissioned to look into behaviors in virtual worlds. She has an interesting report here regarding the behaviors that were found.
When I spoke with her – the majority of my questions were around: How, when, what. This was just an initial peek for the FTC into behaviors, and much of what they found was from first time viewing. We talked a fair bit about COPPA, and what was next for the FTC.
Both Congress (on April 29th) and the FTC (June 2nd roundtable) are re-examining safety and privacy – and what that means from their standpoint. Okay, their standpoint… but what about OUR standpoint, what will that mean for us?
- COPPA HAS NOT CHANGED.
- Talks are beginning: People are looking to open up conversation, reassess, get feedback about COPPA
- If changes are made to any part of COPPA it will not be immediate
- If COPPA does receive some changes, adds, tweaks, deletes – it will have a “Goes into Effect” date
- If there is a “Goes into Effect” date – companies will have a GRACE PERIOD in which to react
- But most importantly: NOTHING HAS BEEN PUT INTO LAW YET. And regardless of any rumors regarding: “So and so said this” or “I heard that the FTC has already decided” – etc. Stop perpetuating rumor that scares others into reacting.
IF COPPA changes, it will probably change due to parent verification – either attempting to find better methods of verification or deleting old methods of verification considered ineffective.
This shouldn’t affect any LIST (be it black, white, etc) that you have on your site. As long as kids who ARE NOT PARENT VERIFIED are set to default “Scripted Chat” (or pre-written chat) you’re fine. DO NOT ALLOW KIDS TO CHAT (filters or no) WITHOUT VALID PARENT VERIFICATION. How to do that? Talk to company offering the Safe Harbor program. Lawyers know a lot – but they’re NOT workin’ on this side of the biz daily, and it’s basically they’re job to be paranoid about the law (not necessarily how kids are using it). With the exception of a handful (@steph3n , @amymms , @mikepink , Liisa Thomas – yes two i’s, and Jim Dunstan, etc), I’d be mindful. Don’t overreact because of fear. Be proactive in finding out how, why, when, what it means to address kids online, to collect information, and to safeguard kids online (people to follow: @annecollier , @joipod , @twizznerd , @amymms , @tlittleton , @larrymagid , @shapingyouth , @chasestraight to name just a small handful, there are many more).
You have the parent’s permission – now it’s about upholding that parent’s permission and your brand and the safety of your audience. Robust chat filters are great – THERE IS NO ONE SINGLE COMPANY SELLING THE ONLY APPROVED LIST THAT FOLLOWS THE LAW. If you hear that? That’s bullshit. Straight up. Someone is scaring you into buying a product, and that just breaks my heart…
I would LOVE LOVE LOVE LOVE to get into a discourse about my hopes, intentions, and goals for our industry. I have met some really amazing, dedicated, SMART people – and together we’re continually trying to improve. But when people come in and say things to “sell”? That. Just. Guts. Me. I know I live in the country of capitalism… but that doesn’t mean I have to support it.
I’ve put a LOAD of information in here. My apologies for a lengthy, not so cheeky, probably boring post. But let’s be honest – I needed to ramble on this topic. Clarity is good. If you don’t believe me, or wish to dispute any claims I’ve made… please feel free to GOOGLE COPPA YOURSELF, and/or talk to lawyers AND safe harbor folks. Heck, place some comments, questions at the beep and we can walk/talk through it together.
Taking a moment to GEEK OUT: Muppets
As you know the script for the film was written by Jason Segel (Forgetting Sarah Marshall, How I Met Your Mother) and Nicholas Stoller (director of Forgetting Sarah Marshall), the movie used to be called, The Cheapest Muppet Movie Ever Made, the film is now called, The Greatest Muppet Movie of All Time, which is definitely a much more positive title.
They’re story follows a man named Gary, his girlfriend named Mary and the man’s life-long nondescript, brown puppet best friend Walter must round up and convince the now retired entertainers from the original Muppet Show to help save the famous television studio that the original variety series was filmed in. The film’s evil villain, Tex Richman, is due to take over the property, and wants to destroy the theater and drill for oil underneath.
Now, thanks to The Playlist we’ve got some more information on the script for the film and what we can expect. Here is a part of their review:
It’s a solid attempt at recapturing what made ”The Muppet Show” and the first two Muppetmovies so great, but “The Great Muppet Movie of All Time” is no ”Great Muppet Caper” — ‘Caper’ being to the first Muppets film, what “The Empire Strikes Back” is to “Star Wars” — but it is a fresh, younger approach. Stoller and Segel have fun with the characters, are aware of what made the Muppet early years so great (winks to the audience, friendly musical numbers, single gag repetition, friendship and togetherness being the answer to everything), and hit the mark 65% of the time. We’re hoping the songs (the majority of which were missing from the script) help elevate the script from a harmless Muppet flick to a more memorable one, but there’s more work to be done first. But what their script lacks (oddly enough, this being a Muppet movie and all) is forward pulse. ”The Muppet Movie” is about a frog’s drive to get to Hollywood and the people he meets along the way and the friendships he makes.
The person that read the script definitely isn’t 100% sold on the script. Perhaps the script he read is a first draft and has since been polished. I’m still holding out for hope that it will end up being a good, solid, fun Muppet movie. Make sure head on over to The Playlist to read the rest of the review.
more-details-on-jason-segels-the-greatest-muppet-movie-of-al.html from geektyrant.com – StumbleUpon
Yes: I do realize that this isn’t the “most glowing” of script-review previews… but I don’t really care (yet, of course – if its crap, hell hath no fury like an izzy scorned). My heart just skipped several beats. I officially do not need coffee now. If a girl could possibly geek out over anything more in the world… there is little that could possibly bring about the glee and joy I am currently emitting.
Ya know, I was psyched for Where The Wild Things Are, and still LOVE that property with all amendments and additions and awesomeness (I have very long, ramble-y tangents about why I still believe in what Jonze did, and the overall WTWTA awesomeness, but they’re best left for another time).
I love the muppets. I am a muppet – or as close to a muppet as possible without actually being made of felt and some stranger’s hand. So forgive me as I take a rather lengthy moment to explain why I – and many of you – could be considered a muppet, and then another moment on why this future edition of the Muppet Movie could be, in fact, like a moment of pure unadulterated youthful bliss – if delivered the way it seems to be promised. So forgive this momentary blog entry, a partial love-letter, in a way… to the Henson (may he be praised).
Like I said. I am a muppet. Hi, nice to meet you.
There are many versions of Muppets in this world – and many wannabe muppet-puppets. Lambchop, you are not a muppet. Clearly. Howdy Doody, sorry bud, not a muppet. Elmo, not a muppet.
errrrrrrrrrrrrrrrrrr, rewind. Yes, I said Elmo is not a muppet. Okay, okay – you’re a muppet, Elmo, I just tend to believe that the Henson (may he be praised) would never have okay-ed a muppet that a) has a “breakout star” attitude for a show about community, b) have a “Me” first attitude, c) look-at-me, look-at-me, show & tell character format, d) is so babyish. Say what you want about the nature of Big Bird and his young voice – but he never seemed to revel in anything babyish, he was always about growing and learning and love and support. Clearly, I have deep seeded issues about Elmo, like one does with a backwater cousin (aw snap).
Anyway – I’m getting off on a tangent here about Elmo that probably will get me in trouble one day with some Elmo-fan.
As I was saying, I am a muppet. So might you be?
Outside of my direct family, the entity that affected me most in life would have to be the worlds and lessons and community of Jim Henson (may he be praised) (we’ll leave my TV family, the Cosbys, and the epic Disney for other conversations). Henson, in many ways, taught me:
1. Acceptance (of yourself, and others, yet the push to reach for your dreams and not accept what you don’t want for yourself)
2. Cultural diversity (I’ll have to ramble on this particular point some time)
3. Simple lessons (near, far – COME ON, it’s BRILLIANT)
4. Love & Friendship (you can complete anything with your friends)
And most importantly: Community (the sum of 1 – 4)
Community was at the base of anything I’ve ever seen from Jim Henson (may he be praised) – it was about people: diverse, unique, the same, friends, soon-to-be-friends, group triumph, etc – the story of “together”. I may be a “kook”, but I’m not alone – there are other like-minded (or complimentary alternative) kooks that you’ll come across in life. Acceptance of others is also, sometimes, acceptance in self – love people for what they bring in your life, and the adventures they accompany you on, and the support they provide – and oh, the laughs of it all!
It takes all kinds of people in life – all kinds! And if Jim Henson (may he be praised) not only presented this concept to you, but also empowered you to express your addition to community, both large and small (whether it be with silliness, creativity, support, and/or acceptance), then yep – you might just be a muppet too
Now, enough about me explaining my muppetude. After the Henson passed (may he be praised), the Muppets (all Muppets) had a heck of a rollercoaster ride – what with Sesame Street going one direction, and the Muppets (Piggy, Kermie, Gonzo, Foz, et all) going quite another (finally ending up in the lap of Disney). There have been many movies – some cute (I do love Muppets Treasure Island), and some slightly lost at the heart (Muppets From Space), there have been television shows (the two attempts at reviving The Muppet Show), and many, many commercials (Piggy supporting Pizza Hut… um… Sausage Pizza, Piggy… not ideal for you). Somewhere in my soul, I can’t help but fear that the Henson wouldn’t be too happy to see his creations hocking Disney products – or any product, for that matter. Some Muppets were created (Jim Henson Creature Shop simply must be a magical place) for alternative programing (I seriously began watching Farscape only for the muppets), and keep alive a beautiful form of art that CGI seems to want to destroy (ugh, don’t even GET me started on how I feel about the lack of muppets in Star Wars: Ep 2 & 3).
For the last year, The Henson Company and Henson Studios have been slipping further and further into the new age of viral content – and THANK GOD FOR ME. From Twitter – @hensoncompany & @muppetsstudio, and @muppetnewsflash and @muppetcentral, to Youtube – youtube.com/MuppetsStudio, where they’ve been delighting muppet-loving-viral-audiences with hilarity – on the street vids, music vids, Waldorf & Statler doing what they do best, and clips. This is the first time in a LONG time that I’ve seen the original Muppets doing what they do best – silliness and fun.
But there’s no connector piece – no full-stage, chaos. No collection of diveristy & no drive forward in some representation of teamwork, community, and sense of togetherness that can be seen in the old TV show, or in the movies – the review that Playlist has in the clip I snagged above clearly points this out. Adventure – the linear path of adventure. The beginnings and middles and sad-to-be-leaving, endings. This is the make or break for Muppet movies that seem to achieve the tone we all like, but feel “flat”.
I watched the “director’s commentary” version of Forgetting Sarah Marshall a year or so ago – and I particularly remember the mention that Jason Segel is a HUGE muppet fan, and that he geeked out massively when he got his Drakula muppet (um, who WOULDN’T, I mean, really – IT’S A MUPPET, a girl could only wish!). I can’t help but feel that Jason Segel is of muppet origin, just as I claim to be (perhaps, a wee different version, but still). I commend anyone for taking on a massive undertaking like a Muppet movie – for me, it’s like drinking my own koolaid and trying to predict what happens next. In other words, I couldn’t do it, not faithfully, and I’d get WAY too caught up in playing out stories, like an 8 year old with her Barbies, to be able to give it a fitting and concise story. I’d want it all, neverending, and repeat, lol.
I really do hope this movie gives a fitting nod to the Muppet dynasty. Really, truly. Sometimes I wonder if the youth today are benefitting the way I did from the Henson (may he be prasied). How horrible it would be to be raised without Cookie Monster who eats COOKIES (not freakin’ fruit), Big Bird and Telly, Oscar the Grouch, best buds Ernie and Bert, and Snuffy – both imaginary and real, Kermit and Fozzie Bear, Ms. Piggy (who came to my 8th birthday – best visitor ever), and my BELOVED Gonzo, not to mention Sam Eagle, Waldorf/Statler, the entire Muppet show ensemble, Ludo and cast (The Labyrinth), and all of the realistic characters from The Storyteller – which, had one of the LARGEST impacts on my imagination of all time (save that story for another reason).
Okay, I’m realizing I could keep going with this… I should probably end awkwardly now with no closing point, as I feel this topic is going to keep bubbling up over the next year. But before I do:
Please feel free (if you made it THIS far in this love-letter-ramble) to comment on your favorite Henson reprocussions of your life, or in general!! I’d love to hear it. I’m fascinated with how one puppeteer subtly altered our generation and entertainment….
