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An Izzy-torial: ADD N Me

October 11, 2012 2 comments

So, recently I’ve been experiencing moments of mental “fubar”-ness.  There’s rhyme and there’s reason for it, and it goes well beyond what I chose to discuss today [there's a time and place to discuss heartache, personal frustration, and bereavement - and its called 'vague facebook statuses' Lolzerbot].  But, I digress…

In my attempts to logically understand some of the chaos I’m trying to sort through in my brain, I’ve come back to a small nugget of a “disability” (and I use that term lightly, as it’s more of a “unique ability”) I’ve grown up with… and that’s what I’m going to dive a bit into. Oh bless cathartic posts.

If you have ADD (Attention Deficit Disorder), or a child with ADD, or a loved one with ADD… maybe what I will share will help you understand a bit of process or frustration they experience.  This is, of course, just my point of view… but you never quite know who may identify with it.

College photography “self portrait”.
There’s a whole lot of “god knows what” going on in that brain/expression.

I grew up with ADD (and no, against popular belief, NOT ADHD), and I probably still have some forms of adult ADD.  I do not conceptualize the knowledge around me the way that others might consider “normal” (case in point – the phrasing of that statement), or in a way that the greater populous might understand/identify with.

“Nobody realizes that some people expend tremendous energy merely to be normal.” – Alber Camus

Before I was diagnosed at age 10 with ADD, I was “not correct”.  Weird statement, right?  Lemme explain: I didn’t hear things the way they were meant to be, I didn’t understand directions the way they were given, and I didn’t complete tasks the way they were required.  Not on purpose, mind you.  You know the phrase “reading between the lines” – it was as if I’d read all the wrong parts, heard non-existent intentions, created context unsaid, and imagined another method for an end result (an end result of my own determination).  None of these were consciously chosen.

It was very difficult trying SO HARD to be a good student, a good child, a good person when my interpretations were SO far off.  Which goes back to – I was incorrect.  I’d go as far to say – I was incorrect about 65% – 75% of the time.  Not very good odds, and very hard on a mushy child’s brain in the middle of “formation”.  And I haven’t even introduced the fact that I was a stubborn force-to-be-reckoned-with, if not “passionate” child.

The “less awesome” things I learned (or adapted to) from having ADD (tough to swallow for the aforementioned child):

  • Never immediately trust my (first) instincts,
  • The majority of the world is “correct”, and I am not ,
  • “At least my failure is well-intentioned”,
  • With context and lots of over-explaining, I too can curb my understanding to eventually match everyone else’s!

When I was diagnosed with ADD – it was a bit of a god send.  I wasn’t stupid, and I wasn’t lazy (as were mentioned by some twit-teachers).  I had something to cling to – an explanation, a CONTEXT of why I wasn’t “correct”.  We started seeking alternative methods to help support my learning disability – finding my strengths in the play patterns I naturally gravitated to — STORIES.  Me and my world-o-Barbie?  Oh man, no Soap Opera could have EVER compared to the epic, dynamic events that I created in my own wee little world.

Nothing was EVER so powerful as the opportunity for fantastical creation by an imaginative child grasping at “reality” straws.  

I made my rules, I made the logic, I got to play GOD and I learned what it felt to be CORRECT. Yay for self-contrived self-confidence! (Lol, sure, but its true).  Additionally, writing provided me an opportunity to appeal to others with context, emotion, and creative expression – I discovered the existence and the magic of possibility through another perspective. WHAT? Two people can be correct but with different statements? <- strangely, this is a foreign concept to SOME children who end up having to go by structure and set-statements made by others because they were always made to feel inferior, stupid, or incorrect.

It wasn’t until I started taking my creative writing in college seriously that my soul blossomed and life started to FIT.  With a little creative logic, I was able to give context and structure to the things in life I was misunderstanding or failing.  With story – it was no longer “memorize this word because everyone else understands it”, but facts and information became tools within a larger story that formed a general understanding – one that I created and could identify with (or “understand”).

Things I learned that benefited me long-term:

  • Imagination is so powerful in the entertainment world (occupationally speaking, lol)
  • Self-deprecation & humor
  • The ability to apologize & accept responsibility (this is actually a fault too, as I’m quick to appeal for an apology for things I shouldn’t apologize for… but I prefer to assume responsibility myself, then be accused)
  • Mediation (beyond people, but mediation of differing concepts)
  • Reading people and treating judgements carefully
  • “There’s always another way” – one door closes, there’s probably 12 more down the hallway (if you will).
  • Question. Everything. But respect the populous for their structure.
  • EMPATHY EMPATHY EMPATHY

The strange result of me HAVING ADD, and me ADAPTING my ADD to the world is that I approach everything with 2 reactions.  This can be very tiring, and at times like a thunderstorm of frustration internally.  Occasionally one perspective comes swiftly – like a locomotive train, full of tunnel-vision and speedy determination (and if proven wrong… the subsequent reaction is just as powerful with spiraling questions and epic self-doubt), while the other moseys through the devil’s advocate debate of context and understanding like a Sesame Street skit of silly, imaginative rationals [this is near, this is far. Near. Far.  See it?].  Also, when the spotlight is on and your knowledge is questions – there’s a certain measure of insecurity and defensiveness that can come through — but that’s not too far off from how the majority of the world feels, I know.  The difference is… growing up with ADD, you already know that you’ve been proven to be “wrong”, and you know the world knows you have a greater % of actually successfully being accused as such.  Sure that definition of “wrong” changed over the years to a “unique perspective” (empowerment) – but there are times you can never shake that 3rd grade F because you misunderstood the question or the directions.

I’m thankful for a great many things that ADD empowered me with — as it was a fault that increased my talents.  But learning how to “overcome” is much like “success” – it’s a path, a roving goal, and rarely a destination.  So, maybe I don’t have adult ADD, and maybe I’ve learned how to adapt to certain things in life… but that doesn’t mean that events from childhood ever truly go away.  Every action has a change for thousands of reactions… some you don’t see right away, and some you live with every time your feet get nailed to the floor.

Find outlets, support each other, be empathetic, be certain, and be creative – and help others do the same.  I think I have to learn a bit more about self-forgiveness, and I would encourage you to do the same for your child who may or may not have ADD.  There’s no better way to end a post like this then with one of the BEST quotes of all time, from my person deity – Jim Henson:

“Watch out for each other. Love everyone and forgive everyone, including yourself. Forgive your anger. Forgive your guilt. Your shame. Your sadness. Embrace and open up your love, your joy, your truth, and most especially your heart.”

It’s Arrived! FTC’s Proposals for COPPA amendments

September 15, 2011 1 comment

FTC Seeks Comment on Proposed Revisions to Children’s Online Privacy Protection Rule Changes in Technology Drive Proposed Updates

The Federal Trade Commission is seeking public comment on proposed amendments to the Children’s Online Privacy Protection Rule, which gives parents control over what personal information websites may collect from children under 13. The FTC proposes these amendments to ensure that the Rule continues to protect children’s privacy, as mandated by Congress, as online technologies evolve. The Commission proposes modifications to the Rule in five areas: definitions, including the definitions of “personal information” and “collection,” parental notice, parental consent mechanisms, confidentiality and security of children’s personal information, and the role of self-regulatory “safe harbor” programs.

FTC Seeks Comment on Proposed Revisions to Children’s Online Privacy Protection Rule Changes in Technology Drive Proposed Updates

Wow… so, after a year of research and reflection from the COPPA round table in DC, the FTC has come forward with some proposals / amendments to the Children’s Online Privacy Protection Act.  This should be VERY interesting, considering the upcoming push for kids to participate in Social Media platforms (*cough* Hearsay… Facebook *cough).  Take a look at the link above for full run down from the FTC website. Otherwise, here’s a quick bullet list.

Proposed changes include, my notes in RED:

  •  Updating the definition of “personal information” to include geolocation and persistent identifiers such as tracking cookies for behavioral advertising. (Wow. I actually think this is GREAT for all those platforms now collecting location.  Seems like a no brainer in regards to children.  As for Behavioral Advertising?  Man oh man, this should be an interesting shake-down.)
  • Modifying the definition of “collection” to allow children to participate in interactive communities without parental consent. (Sites must employ reasonable measures to delete all or virtually all children’s personal information before it is made public) (I’m not sure how different this is from what is already practiced?  I will need to do a deeper dive to understand what this is in exact reference to, or what this actually affects – if anything at all).
  • Streamlining/clarifying information that websites give parents prior to collecting children’s personal information (adding more information in the notifications, and not hiding in only in the Privacy Policy) (This is great in “theory” – but let’s be honest… it’s hard enough to get parents to see the BIG GREEN CLICK HERE / URL at the TOP of a welcome email, regardless of the information buried within the email.  I feel this is a “good policy” amendment more than something that will prove helpful, which is sad.)
  • New Parental Verification / consent opportunities (Yay! we need new methods!):
  1. Electronic scans of signed parental consent forms (The modern “fax”, lol.  No brainer here.)
  2. Video-conferencing (Bwaha! Dear gawd almighty – this is BONKERS for scaling… Great for quick-fire Customer Service & Skype, nuts for staffing and sustaining large groups)
  3. Government-issued IDs checked against a database (note: promptly deleted after verification) (Interesting! Lots of “Big Brother”-esque thoughts stream through my head, and I don’t necessarily think its a bad thing in regards to children… But that’s because those actions help me do my job in protecting my audience).
  • PROPOSED DELETION OF EMAIL-PLUS (This is a HUGE FTC proposal. It could affect a LOT of businesses and platforms for kids. Seriously.  Not to mention, marketing emails & virtual worlds… People who have been using email plus + great policy are about to lose a LOT of numbers in registrations!  Oooo doggy!)
  • New 180-day proposal for companies seeking “new” types of verification processes to be vetted and approved (or rejected) by the FTC
  • Safe Harbor programs must do annual audits. (Um. Yeah. I feel like there should be biannual audits done, but in a cooperative, friendly manner.)
Overall – interesting day of information.  Commenting has started on these proposed amendments… so get on it if you feel the need to speak out.  The only yellow flag for me = deletion of Email Plus.  It has been the EASIEST method to engage kids… and the lowest barrier to entry for parents (*no comment on the easy work arounds).  I worry that this will just send kids tenfold into adult areas or into opportunities of lying to get what they want.  Overall, maybe it will be a great thing?  I think I’m just foreseeing the crunch various companies are going to have between removing the “email plus” approval system and entering the “full verification” method.  I know a lot of companies have used email plus in a positive method – with extensive filters, moderation systems/practices, and staffing.
So… what do you think?

Zuckerberg wants children under 13 on Facebook?

May 20, 2011 1 comment

Zuckerberg said he wants younger kids to be allowed on social networking sites like Facebook. Currently, the Children’s Online Privacy Protection Act (COPPA) mandates that websites that collect information about users (like Facebook does) aren’t allowed to sign on anyone under the age of 13. But Zuckerberg is determined to change this.

“That will be a fight we take on at some point,” he said. “My philosophy is that for education you need to start at a really, really young age.”

But just how would Facebook’s social features be used by younger children?

“Because of the restrictions we haven’t even begun this learning process,” Zuckerberg said. “If they’re lifted then we’d start to learn what works. We’d take a lot of precautions to make sure that they [younger kids] are safe.”

http://tech.fortune.cnn.com/2011/05/20/zuckerberg-kids-under-13-should-be-allowed-on-facebook/

Here are my first thoughts.

1. PESSIMISM: Of course Mark Zuckerberg wants kids on Facebook – Facebook is a advertising & trend analysis GOLD MINE dressed as a happy, friend-connecting social network.  Kids are the largest licensing group, and advertisers would LOVE to get their hands on that kind of market.

So much for the ENTIRE POINT OF COPPA – which wasn’t created for your immediate privacy, but created to PROTECT CHILDREN FROM MARKETERS STEALING OR SWINDLING PII.

Fail.

Also see: Facebook Forced to Address Legal Gray Area of Kids and Advertising from AdAge. http://adage.com/article/digital/facebook-forced-address-kids-advertising/227633/

2. FEAR: Oh, that’s a GREAT idea.  Why not make more PERSONALLY IDENTIFIABLE INFORMATION ABOUT MINORS available?  Tre sigh.  Yes, education is VERY important – particularly about secret identities.  But, children under the age of 13 DO NOT HAVE THE COGNITIVE CAPABILITIES TO BE SOLELY RESPONSIBLE FOR THEIR PUBLIC PERSONA.  Part of being young is that you’re protected and allowed to make mistakes – by allowing that on Facebook – a public platform that reaches far beyond the lunch room, and far beyond your mom telling your aunt about that stupid detention you got?  BOO.  Not ideal.

3. LOGISTICS & CONCERNS: MODERATION. SCALABILITY. COST. Even if Facebook DID man up and start pre-screening all content contributed by U13 sources, what a nightmare!  Staff to cover something like that?  Insane.  And neither revenue nor cost efficient.

4. HOPE: Any sort of “educational program” that comes with U13 on Facebook would have to be an entire new entity.  Think: Facebook Junior, profile training wheels.  It would have to be limited, with tutorials and information, and educational guidance.  Leverage the sort of YouTube content that SweetyHigh has created (worth checking out).  But in no way, would Facebook be able to cruise right into allowing U13 without redesigning the fundamental/core use of Facebook.

4. REALITY: I deal EVERY SINGLE DAY with kid chat, and kid posts, and kid interactions, and behavior crises from U13.  I worry about social networks for children that do NOT rely on fantastical role play or themed-content.  Those two elements help protect direct attacks (or even mistaken, indirect attacks) on a sensitive and underdeveloped child by allowing creative persona & identity hiding (to a certain extent, of course – real friends playing in fantasy worlds blends that reality vs role play, and takes interaction to a different level).  Children are still in the process of social learning.  Social learning CAN be expanded – and I do applaud the idea of social network education… but tossing youth into the deep end, where there are daily Trojan attacks on accounts, stolen identity issues & account phishing, cyberbullying, advertising lures, and STRANGERS is not ideal.  Think about it: not even normal, rational adults can successfully navigate Facebook accurately…

If there is a way for Zuckerberg to incorporate social networking education, with Facebook structure, I’m eager to see it – but there are quite a few MASSIVE problems in his path.  And with this audience?  Bowling through the ideals without proper guidance, understanding, or safety nets = not a safe agenda.

I hope Zuck collects his facts, has the necessary research concluded, and (excuse the phrase) gets his shizzz straight before he really dives into something like this.  For as much as I applaud optimistic philosophy, I desire educated practicality.

Mining for Awesome: Metrics to Identify Your Community

January 26, 2011 2 comments

This fine young man has a different type of impact on the community.  He impacts more users … without his participation, about 2% of the community no longer participates.  He does not impact the total oxygen of the community as much, in other words, he doesn’t impact the number of tweets or number of conversations.  But he does bring along 2% of the community.  And his impact lasts through the forecast cycle, meaning he impacts new participants as well.

This exercise can be run for every user in a community.  We can easily forecast what impact each user has on the overall future of a community.  By looking forward, we get to see what might happen, and we can take steps to change the future.  When we simply look back into the past, we only measure what happened in the past.

In this simple example, when we remove just two users from a community of about four hundred weekly participants, we lose close to 8% of all future activity in this community.  In spite of a ton of new users, these two folks, @michelehinojosa and @immeria, foster a wonderful and vibrant community.  That’s a decent measure of influence, don’t you think?

Kevin Hillstrom: MineThatData: Hashtag Analytics: Removing a Member of the Community

(Received in Twitter via @TiffanyRichison – my AMAZING Community Lead, who scored it via @TheCR and @mindthatdata)

Over the last year there have been THREE huge benefactors to understanding an audience that I feel like I can’t stress enough:

1. Avoiding the operational FAIL WHALE (oh man, do I have withheld rants on this)
2. Understanding that a competitive site in this industry must have diversity in everything (from gaming, to customizations, to approaching an audience)
3. SMART METRICS

For a few short minutes here, and I stress short, I simply must ramble about the importance of metrics and how our industry HAS to step to bat and start finding the value of users NOT just the abuse.

And when I say “our” industry – I mean specifically the CS, Moderation, and Community.  We need to TOTALLY BFF-up our Metrics peeps… and if there aren’t metrics peeps at your biz, then you need to step up to bat and figure out enough of a base line understanding regarding metrics and analytics to be able to support what you do.

Why? WE’RE EXPENDABLE.  That’s a lie.  I know it, you know it, but there are many a board member who don’t understand why CS & Community & (more specifically) Moderation staffing/tools/practices are so important – POST launch, when the belt gets tighter and the big bucks are takin’ a bit longer to roll in.

We’re just people who manage people – anyone can do that… interns can do that, right? PUUUUUUUUUUUKE.

WRONG. UGh. Shudder. Frustration + fist at the sky with some sort of user engagement battle cry!  Just because you have a background in marketing – that doesn’t mean you have that GUT understanding, nor ability to read a community.  Marketing folks can spin statements and emphasize the value of advertising and approaching product, but it’s not the same [...feeling another tangent coming on. Must jump off this tangent path, my apologies].

What was I talking about?  Oh yes, Metrics.  Analytics.  Whatever you wanna call it – basically, this day and age those of us people-people need to have back up.  Stories are fun for conferences and for nailing a point home.  Leaderboard-esque insight into top players is great to show your front-line knowledge of the audience’s ability.  Social media platforms and conversations are great for keeping the product within fingertips of users everyday conscious.  But when it comes to number crunching – dude bettah getz some backup. For realzies.

So far, metrics have been great for game designers and registration flows.  It’s been great for microtrans and heatmaps (which, may I say – I love me some well developed heatmaps).

Blargh – OKAY, I’m biting off more than I can blog-chew at the moment.  I’m going to kinda filter through my metrics conversation from the big point (overall metrics and their importance), and wittle it down to SPECIFICALLY moderation + community necessity.

Finding ABUSE
- Individuals who abuse the system / community / experience
- What is the individual abuse (on a case by case, report, basis)
- Brings questions of WHY individuals abuse: is it the lack of game? Is it the drive of the content?
- Is it a growing group behavior?
- What exactly is the abuse of this growing group behavior?
- Brings again the questions of WHY individuals abuse: is it the lack of game? Is it the drive of the content? Is it the lack of appropriate competitive interaction?  CAN YOU FIX THIS?

Finding VALUE
- Individuals who represent the best of the community
- Individuals who engage from within
- Individuals who lead by example
- *Individuals who seem to be the best of the best, but actually become somewhat cancerous in their righteousness and maybe should be used as a best case
- Groups who lead by example
- Groups who promote desired community efforts
- Areas that promote desired goals for game or specific area
- Individuals or areas that can help promote the MONETARY VALUE OF UPGRADING (via microtrans or subscription)

Remember – you want to gently lure and entice users into becoming monetary assets… and not just monetary assests but SUPER USERS.  For as gross as statement from a “purest” perspective as that is… YOU CANNOT RUN A GAME WITHOUT INCOME.  Just can’t.

Why would you just use metrics for landscapes and game agendas, or finding bad users?  Dude – it’s the day and age of community! Of social media!  Own it.

BALANCING THOSE OF ABUSE AND VALUE
Just as this AWESOME article above points out – not all users are just “good” or just “bad”… Use metrics and analytics from:
- Chat (a filter that reads positive chat and associates percentages, a chat filter that reads abusive chat and associates separate percentages)
- Interactions (Community event item clicking and purchasing metrics, guild-grouping, chat submissions, logins, time spent online, friending, time spent in social areas, time spent in gaming areas, time spent multiplayer gaming/interacting, leaderboards, time spent in “home” areas customizing, etc)
- Friending – viral quality outside of game, as well as inside the game.

If you are in the MMO or VW space… I would SERIOUSLY suggest taking a moment to have a solid “think” regarding understanding the bookends of your community, and the elements that drive the bulk middle either direction over the course of their experience.  The more you can automate that process for your moderations, customer service reps, and community managers – the stronger / swifter / and better the process will be for you!!  You will still need the insights and stories and multisocialmediaextravaganzamadskillz of community pro’s – naturally.  But you also need number crunching and proof of pudding products.

So, my dears, in this slightly confusing, probably ADD fueled post – my point is this:
Community and Moderation and CS folks… go rogue for a moment, totally ninja-BFF any metrics/analytics people on staff.  Make tools or practices that will help you to find the value, find the abuse, and back it up with the best kind of numbers you can find… AND THEN use your mad community skills to help understand why numbers show what they show, and improve your audience, your product, and the WORLD.

Make sense?  Hope so.  If not, as always, leave a comment at the beep……

Beep.

Engage! Expo Conference Prezzie

September 27, 2010 1 comment

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 ;)

The Conundrum that is Planet Cazmo

August 2, 2010 6 comments

Planet Cazmo is going to partner with Fox’s Teen Choice 2010 awards and entertainment mogul Tony Mottola to create a custom virtual environment called the Virtual Teen Choice Beach Party. The special virtual environment will be directly accessible from a link on the Teen Choice Website. The Teen Choice 2010 awards will air August 9 at 8 EST on Fox Users will be able to visit the virtual beach party after casting their votes online.

In the Virtual Teen Choice Beach Party, users will be able to design an avatar and a virtual home. In the virtual world, users can chat, play mini-games, virtually dance, and even purchase virtual goods. One of the goods for sale will be a branded good shaped like the award show’s signature Teen Choice Surfboard. This won’t be the first virtual event Planet Cazmo has developed for a major brand or celebrity partner. Previous projects developed by Planet Cazmo were primarily virtual concerts or music-themed, though.

Virtual Teen Choice Beach Party

Okay… So, wow.

First, I do find it absolutely RAD that Planet Cazmo has broken the start-up, non-uber-brand IP curse and managed to score such a marketing bonanza as TEEN CHOICE AWARDS on Fox.  That’s kinda huge.  Brings in the eyeballs – aka, sudden brand awareness.

For the last two years I’ve watched Planet Cazmo score quite a few influential contracts with big music peeps… They’re freakin’ email machines – no one sends as many newsletters as this site… seriously.  There is always something going on it seems.

The art is easy, not too complex. The world is expansive (almost too expansive, but they try to pack everyone into the same server- providing the PARTY! feel of busy-busy).

Again, I’m still floored by their marketing department and promotions… well played for such high profile awesomeness.

PROBLEM: I just logged in as a minor and was able to share “my” phone number (or, ya know, the Empire Carpet guy’s number, five eight eight two three zero zero), “my” address (or, ya know, the white house), amongst other things.  Then I created another account, logged in, and watched myself say the same content all over again (aka, the public can read it, its not just author-only jedi-mind-trickin’).

At least they caught “shadows are as dark as holes” – but as holes, for as swarthy a curse as it is in kid land, is NOT A LEGAL PROBLEM.

I can’t believe I just logged in, approved my “child” via email plus, and then passed out faux-personal information.  What the what?!  AND THEY’RE GOING UBER-PUBLIC WITH A TV SPONSORSHIP!  It makes me very, very nervous for them.

Talk about disappointed.  I’ve been dealing with several companies lately that are looking to ensure that they’re sponsorships/partnerships/etc with youth virtual worlds are LOCKED DOWN and safe… why the heck didn’t Fox check into the legal nature of Planet Cazmo?

I’m still absolutely astounded that I could give addresses and phone numbers. Baffled, even.

Blogged with the Flock Browser

Let’s Chat: COPPA

April 25, 2010 5 comments

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?

  1. COPPA HAS NOT CHANGED.
  2. Talks are beginning: People are looking to open up conversation, reassess, get feedback about COPPA
  3. If changes are made to any part of COPPA it will not be immediate
  4. If COPPA does receive some changes, adds, tweaks, deletes – it will have a “Goes into Effect” date
  5. If there is a “Goes into Effect” date – companies will have a GRACE PERIOD in which to react
  6. 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. :)

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