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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. :)

Connect Safely Kids’ Virtual World Safety Tips

January 11, 2010 1 comment

Virtual worlds are online spaces where kids create avatars (kind of like cartoon characters) through which they communicate, socialize, learn, shop, play games, and generally express themselves. There are hundreds of virtual worlds on the Web aimed at users of all ages. Some aimed at young children have controlled text chat, “profanity filters” to block offensive or sexually related chat, and staff or contractors moderating user behavior – you’ll want to check for these safety features. Parents also need to know that there are worlds kids can find and access which are not designed for them.

As with all kids’ online experiences, the No. 1 safety practice is routine parent-child communication. Keeping it low-key and frequent helps our kids come to us when stuff comes up. The most likely risks in kids’ virtual worlds, just like on school playgrounds, are cyberbullying or peer harassment and social-circle drama – including clubby behavior and kids playing “teenager” and talking about “boyfriends,” “girlfriends,” “breakups,” etc. The latter escalates and gets more sexually charged as they head into middle-school age. Language filters help, but kids can be creative with workarounds (see below). The main thing you need to know is that virtual worlds are user-driven: Positive experiences depend on users’ behavior toward each other and how well the space is supervised. Here are some pointers for safe, constructive in-world experiences.

Connect Safely |Kids’ Virtual World Safety Tips | Safety Tips

I truly suggest you head over to Connect Safely’s tips for navigating kid virtual worlds as a parent (and kid). 

Anne Collier, esteemed author, is amazing and is always watching these area with her eagle eye and brilliance. 

The trends and behaviors of kids online are always changing, and yet not changing at all.  It’s  like a tag cloud – there are all sorts of behaviors a foot and they’re always floating around… they just take turns in the “who gets to be the biggest issue”.  It’s never a stale world, my friends – probably more cyclical than anything else, but there you have it… kids. Lol.

I can’t stress to you HOW IMPORTANT it is to understand many of the safety tips that Anne points out.  SHARE THEM. Seriously…. SO MANY PEOPLE ARE SEVERELY UNDEREDUCATED or MISEDUCATED regarding the crazy world of web social media.  It’s easy, it’s hard, its crazy, and it’s exciting, and all shades of each. 

Pleeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeease pass that link to any / all of your friends with kids, working with kids, etc. 

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Lookie Lookie: Wizard101 has the cookie!

January 7, 2010 Leave a comment

One game, however, stood out among the rest as the Best Family Game of 2009. The nominees were:

  • Club Penguin
  • Free Realms
  • Fusion Fall
  • Maplestory
  • Wizard 101

The Winner: Wizard 101

Wizard 101 has been heralded as the kid’s MMO for adults. The game is geared toward a younger audience with its playful characters and cartoon graphics, but don’t be fooled by its exterior. Inside Wizard 101 is an intense MMO that uses great special effects for spells, daring and risky card game style combat, and a fun universe to explore for players.

The reason Wizard 101 takes home our Best Family Game of 2009 is because kids can play it with their parents and no one will be bored. Hardcore MMO players have come forward and said the game is fun and exciting to them as well.

Wizard 101 : Best Family Game of 2009 – Wizard 101 for PC at MMORPG.COM

LOOKIE LOOKIE, WHO HAS THE COOKIE!

YAHOOOOOOOOOOOOOOO!  I am really pleased with this out come.  For as much as I still nod-in-appreciation to Club Penguin, this is really a well-deserved win.

Think about it:
Wizard101 came from an independent company without broadcast support (aka, no big dog marketing pushes, like Disney / Cartoon Network / MTV / Sony, etc).  It was smart enough to find an IP that could be both independent in content & game play, but also capitalize on a desired-yet-missing brand (HARRY POTTER, PEOPLE). 

It’s got boy game play, girl game play, school play, card play, and it effectively finds ways to suck a wallet drive (subscription only gets you so far – potions & rides/mounts are extra $$).

It’s the MMO I play as often as I can, and because I ENJOY playing it – not just for work / research.

What I’d like to see Wizard101 do in the next year?
1. Make houses more important – why do I care I’m in the Fire house? Why do I care others are in the Fire house?  Give me reasons to be Fire-House-Evangelist in the game, please!

2. Change the chat set up.  By “redding” out the words that I cannot use – you are giving me clues to work-arounds.  OH, I can’t say “dork”? Well then, let me try “door k” DONE. Thanks red for telling me WHICH WORDS weren’t allowed, and confusing me other times when you’re not allowing me to say something I need to say (like “fizzling”).

Other than those two wee things – keep on keeping on, Wizard101. I’m psyched for you!!

ON a SIDE note… why the heck is MapleStory in there? Um, last time I played that game a guild named “Pedophile” was causing rukus through the servers… Kids swear like they’re afraid its going out of style, it’s Ad Mad, and it’s not family appropriate.

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Virtual Worlds and Youth: Accessing Explicit Content

December 10, 2009 2 comments

FTC Report Finds Sexually and Violently Explicit Content in Online Virtual Worlds Accessed by Minors

Recommends Best Practices to Shield Children and Teens

The Federal Trade Commission today issued a report that examines the incidence of
sexually and violently explicit content in online virtual worlds. The congressionally mandated report, “Virtual Worlds and Kids: Mapping the Risks,” urges operators of virtual worlds to take a number of steps to keep explicit content away from children and teens, and recommends that parents familiarize themselves with the virtual worlds their kids visit.

The report analyzes how easily minors can access explicit content in virtual worlds, and the measures virtual world operators take to prevent minors from viewing it. According to the findings, although little explicit content appeared in child-oriented virtual worlds, a moderate to heavy amount appeared in virtual worlds that are designed for teens and adults.

Virtual worlds are popular with children and adults because they blend 3-D environments with online social networking, allowing users to interact in and shape their own online content. Through avatars – digital representations controlled by humans in real time – virtual world users socialize, network, play, or even conduct business in graphics-intensive landscapes using text or voice chat, sounds, gestures, and video. Despite the educational, social, and creative opportunities virtual worlds offer, the FTC’s report found that explicit content exists, free of charge, in online virtual worlds that minors are able to access. In fact, some virtual worlds designed for teens and adults allow – or even encourage – younger children to get around the worlds’ minimum age requirements.

“It is far too easy for children and young teens to access explicit content in some of these virtual worlds,” said FTC Chairman Jon Leibowitz. “The time is ripe for these companies to grow up and implement better practices to protect kids.”

The FTC surveyed 27 online virtual worlds – including those specifically intended for young children, worlds that appealed to teens, and worlds intended only for adults. The FTC found at least one instance of either sexually or violently explicit content in 19 of the 27 worlds. The FTC observed a heavy amount of explicit content in five of the virtual worlds studied, a moderate amount in four worlds, and only a low amount in the remaining 10 worlds in which explicit content was found.

Of the 14 virtual worlds in the FTC’s study that were, by design, open to children under age 13, seven contained no explicit content, six contained a low amount of such content, and one contained a moderate amount. Almost all of the explicit content found in the child-oriented virtual worlds appeared in the form of text posted in chat rooms, on message boards, or in discussion forums.

FTC Report Finds Sexually and Violently Explicit Content in Online Virtual Worlds Accessed by Minors

HEEEEEEEEEEEEEERRRRRRRREEEEEEEEEEEEE WE GOOOOOOOOOOOOO!

Okay, for as much as I would love (and you know I would) to ramble ramble ramble about my opinions on this piece, I am going to stay MUM.

Why, you ask? Well, because according to engageexpo.com, I am (and very happily so) speaking on this VERY topic with Phyllis Marcus, who was commissioned by the FTC to research and report on youth and virtual worlds.

Safety in Online Worlds: How the Federal Trade Commission Sees It
In March of 2009, Congress mandated that the Federal Trade Commission study the types of content available in online virtual worlds — paying close attention to explicit sexual and violent content — and the mechanisms those worlds use to manage access by minors. In this unique session, the Commission’s senior most attorney assigned to the 2009 Virtual Worlds Report to Congress will present results and discuss the agency’s recommendations for strengthening access controls to virtual worlds while allowing free expression to flourish online. This first-ever analysis of virtual worlds by the FTC will be discussed by senior attorney Phyllis H. Marcus who heads the Commission’s children’s privacy program and is responsible for enforcing the Children’s Online Privacy Protection Act (COPPA). Marcus expects this session to be the first detailed public reveal of her division’s nine-month study of virtual world content. She will present data, offer recommendations, and participate in a lively one-on-one interview with virtual world child safety advocate and online community activist Izzy Neis.
Phyllis H. Marcus, senior attorney, Div of Advertising Practices, FTC’s COPPA lead
Izzy Neis, Senior Community Safety Lead, Gazillion Entertainment

http://www.engageexpo.com/ny2010/schedule/track2.html

Score, right? Right. Couldn’t have asked for a better opportunity :)

I’m looking forward to this, especially after reading the article on the FTC page, and subsequently skimming through the document while printing (it’s a relatively good sized print, fyi).

I’ve never been shy to discuss the social (and sometimes sexual) exploration of youth in free, identity-less (or identity-filled) web environments – from Language play in phrases to bumping to sexting to warplay.  Playgrounds can be a very confusing/odd place for those who do not understand or are not a part of the intricate socialization patterns and learning curve.  And even for those of us who DO understand these same things, it’s still nerve-wrecking and frightening to behold (don’t even get me started on my 13 year old cousin’s behavior on facebook).  But, we react that way because we MUST.  It’s the elder’s duty to help guide and educate the young.  But, that’s not always enough (this doesn’t mean stop, it just means, more is needed).

We cannot expect kids to just inherently know NOT to behave certain ways – especially if that behavior or action can illicit some sort of euphoria or adrenaline rush.  They don’t learn “No, don’t do that” through osmosis.  Fire = bright & warm & pretty & powerful, but you don’t know it hurts until you touch it… you could listen to your folks who say “don’t touch the fire, it burns”, but the curiosity will always be there because you don’t precisely understand the magnitude of “it burns”.

Naturally, someone has to say it – NO, don’t do that.  And when youth refuse to listen (and when they decide to touch the fire), we have to be there to guide, educate, and then PICK THEM UP once they learn their lessons, or after they suffer the consequences… and then, encourage them to share their lessons with others – peer mentorship.

Also, as businesses we need to EMPLOY WELL EQUIPPED, HIGHLY CAPABLE, HIGHLY TRAINED MODERATORS & COMMUNITY MANAGEMENT STAFF… and give them time to DO THE JOB RIGHT.

Moderation is expensive. It just is… Before you even contemplate the idea of “moderation” and how to lower the cost for a teen & younger site – companies really, truly need to accept it.  Say it out loud. Do a little jig. Throw a party. Make a badge and wear it everyone “YOUTH MODERATION AND ONLINE COMMUNITIES ARE EXPENSIVE”, and then swallow that pain.  NO amount of cheating  or pinching the system is going to replace the expense without putting your audience or your brand at risk, UNLESS you employ full restrictions. Full. Restrictions. As in, no UGC – this includes user created avatarnames/usernames, open or filtered or dictionary chat, no pictures, or uploads, no fan fiction, no forums, no blog posts, videos, podcasts, art, nothing. Kinda takes the community out of community, doesn’t it? Yep – remember that jig you did and that badge you wore… there’s your reason.

If a user can type or upload and submit – that’s UGC, and it needs moderation before it ever appears on any live site.

User Generated Content is a privilege for your audience, but also a privilege for your site/brand/ip/experience as a company.  With privilege comes someone else’s responsibility, and that lies with the company to offer opportunity.  Think about it ;)

Anyway… take a look at the FTC article (link above) and follow the white link rabbit to the pdf itself.  Happy reading!!

Annnnnnnnnd, if you’re going to be in attendance for Engage Expo on February 16th & 17th in New York City, please bring some of your lovely and oh-so-brazilliant questions to the 3:30-4:30 chat on Weds the 17th.  I would love to see your smiling faces and bask in your question-filled glory. :D

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Free Realms: All that and the kitchen sink?

May 21, 2009 Leave a comment

For most of the last decade the online gaming market has been
clearly divided between deep diversions for game-savvy adults like
World of Warcraft — which generally cost $15 a month — and cloying,
cutesy fare aimed at prepubescent children, especially girls, like Club
Penguin and Hello Kitty Online.

The sophistication in Free Realms
lies in how carefully it has been designed to appeal not only to both
of those audiences but also to the broad mass of entertainment
consumers who are discovering (or rediscovering) video games through
the likes of the Wii and Guitar Hero.
Free Realms is a bit like a great
animated film: while its core audience may be children, it also retains
enough intelligence and depth to appeal to adults who can appreciate a
little whimsy.

Almost everything about the Free Realms experience
is meant to be as unintimidating as possible. Instead of buying the
game at a store, you just go to FreeRealms.com
on your Windows PC and the client software begins downloading
automatically. The game’s visual style is similar to that of World of
Warcraft, which is to say stylized and colorfully animated rather than
highly detailed and realistic.
Relatively simple graphics allow the
game to run on a broad range of PCs rather than forcing potential
players with old computers to upgrade (or, more likely, not play the
game at all).

Most role-playing games are built around the
concept of classes or archetypes, which determine what sort of
abilities players have at their disposal and what type of activities
they can engage in. A player can choose to be a sword-swinging
swashbuckler or a healing cleric or a sneaky rogue or a mystical
wizard. But those who want to experience different classes must make
separate characters for each one, which can be tedious and annoying.

The
great breakthrough in Free Realms is that your character can hold many
different jobs at once.
You come into the game as an adventurer but
very quickly can assume different roles like medic, archer, warrior,
wizard, ninja or even pet trainer or postman. If you get tired of
racing as a kart driver, just switch over to brawler or chef mode and
try something entirely different. It’s an innovation that much more
complicated games would do well to emulate.

Each of the various
jobs entails a slightly different play style, often built around
mini-games. Mining and harvesting, for instance, involve engaging in a
match-three puzzle game (line up three or more items of the same color)
familiar to anyone who has played a game like Bejeweled. Combat, by
contrast, means using special abilities as one might in a game like
World of Warcraft or EverQuest. Game tables for checkers and chess are
scattered liberally around the countryside as are various additional
mini strategy games.

Video Game Review – Free Realms – Living Nine Lives in Sony’s New Online Game – NYTimes.com

It’s funny, the one thing I found PERSONALLY (not professionally) discouraging about Free Realms when I played was that it seemed to try and be a fantasy world for any & everyone.  I like my context to have some sort of over-arching god-like purpose, not a flimsy “of course there’s a professional looking motor-cross dude in this world of fairies” every-size-fits-all kinda existence… that feels too commercial, too salesy, too $$ in the eyes.

Remember, that’s my personal feelings. 

Professionally? Yeah, it’s pretty smart.  It’s yet another example of a starter MMO for the n00bs.  It has play patterns for all – chess for gramps, checkers for that kid next door, pet taming for the tweens, bejeweled for mom, race cars for cousin joey, guitar hero graphics for the wii-jammers, card play for the pokemon crew, and war for the warriors (ahem, and some dads, ahem). 

Oh yes, and did I mention… U13 – no chatty. None, zip, nada.  U13 can join and play, speedchat yay!  But no UGC communication. Nope.  Not even for parents to unlock.  Scalable solution in the meantime for proof of concept and low overhead on moderation (well, “lower”).  But hey, sweet, right?  And for those over 13 – ignore functions will help!  From what I remember in my playing yesterday, I couldn’t figure out how to individually report a user.  This creates two things (I was playing as an adult, fyi): a) Can’t tattle so i have to deal myself: getting your ADULT community to self regulate is pretty great once it WORKS… takes a bit tho, b) trolls/grieffers are going to be a problemo.

What I find interesting is that – this seems to be one of the first entries into this space that is one size fits all (one could argue Second Life, but I won’t).  I think that Free Realms has the possibility of either spearheading (or being an inspirational nugget that sets off spearheading) a new generation of MMO’s… What I mean is this:

Most MMO/Virtual Worlds tend to BUILD life within the fantasty – it’s own network and community and fantastical existence.  Free Realms is one that seems to USE life within the fantasy- the blend of fantasy with realistic passions on top.  You’re a race car enthusiast wanting to be the circuits best… in a fairie virtual world.  You’re a 5 star Chef… for pets and talking puppies.  You’re a rockstar guitarest… for gremlins.  Do you see what I mean? 

Overall, it’s an exciting venture and TOTALLY work earmarking, eyeballing, examining, and forming opinions about… so go join Free Realms.  I’d love to hear what you think.

Seriously – if you have an opinion PLEASE SHARE!!

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