Children’s Rights and Wellbeing: Executive Summary
The Leadership Position
The rights of every child must be respected, protected, and fulfilled in the digital environment as in the physical world. Innovations in digital technologies affect children’s lives and their rights in ways that are wide-ranging and interdependent, even where children do not themselves access the internet. Advertisers and brands should seek to advertise in a way that is sensitive to these unique needs both online and offline.The Problem
A 2022 study concluded that nearly $11 billion in ad revenue is generated annually by social media platforms from US-based users under the age of 18. In 2017 it was estimated that ad tech companies hold an average of 72 million data points on a child by the time they turn 13, which is an extraordinary amount. Beyond key ethical and child rights issues such as consent, agency and privacy, this datafication can have significant consequences for a child’s development. Children’s internet safety relies on the existence of trusted relationships between online platforms, children, parents/guardians and legislative frameworks, but it is essential that advertisers understand their role in navigating this.Commercial Imperative
Ensuring and respecting child rights and wellbeing enhances a company’s reputation, strengthens risk management, and builds investor confidence in ethical business practices. This commitment extends to all stakeholders, ensuring for a more stable and reliable business environment. Alongside the ethical reasons, adherence to legislative frameworks and systems for best practice helps to risk manage against fines. Developing trust and ethical standards as a brand are more crucial than ever, particularly for Gen Z.Who is this intended for?
This document is directed towards advertising practitioners within agencies and brands and is freely available for all of them to use. If children are your primary audience, you should ensure that child safety is a brand priority, rather than a function or a discipline within a business department. Even if your brand is advertising solely in adult-oriented media, it remains essential to prioritise children’s safety and privacy considerations.How to use the manifesto
Conscious Advertising Network (CAN) supports members on their journey towards conscious advertising, we do not expect immediate perfection. Accompanying this manifesto is the member tracker, highlighted case studies, and a checklist to help support that journey. In line with the United Nations Convention on the Rights of the Child (UNCRC), we recommend that you define a child as under 18 when designing marketing and advertising plans. We have divided the document according to six principles that are inspired by the eleven principles of Child Rights by Design from the 5Rights Foundation.Acknowledging the input of partner organisations
Finally, we would like to acknowledge the input of leading individuals and organisations who have helped us shape this document, ensuring the advice reflect leading global actionable advice for advertisers. We have been honoured to work with groups such as Omnicom Media Group UK, NSPCC, and Bernardo’s, as well as various academics and campaigners. For the list of individuals and organisations that participated, see the end of this page.Guiding Principles
Principle 1: Safety-by-Design – Embed safety-by-design in development and distribution of advertisement
Recommendations under this principle include:
- For brands and agencies to produce an ‘Advertising to Children’ guide which outlines a best-practice approach based on the six principles laid out within the manifesto.
- To closely review any new platforms in your media plans, considering brand safety and whether they align with your values.
- Develop a carefully vetted inclusion list.
- To review blocklists regularly and brand safety processes to ensure your advertisements are not funding platforms or websites that are harmful to children.
Principle 2: Responsible Practice – Comply with legal frameworks and conduct a Child Rights Impact Assessment
Recommendations under this principle include:
- Comply with existing legal frameworks such as the UK Online Safety Act, EU Digital Services Act, Australia Online Safety Act, UK Advertising Standards Authority (ASA) Code of Non-broadcast Advertising (CAP Code), Code of Broadcast Advertising (BCAP Code), Advertising Guidance, USA Children’s Advertising Review Unit (CARU), General Data Protection Regulation (GDPR).
- Consider conducting regular Child Rights Impact Assessment and Human Rights Impact Assessment before the distribution or implementation of digital products or services to mitigate potential impacts on children.
Principle 3: Age Appropriate – Develop and place advertising that is age appropriate by design
Recommendations under this principle include:
- When your advertising collects and uses data, profiling, or targeting aimed at children, adhere to the Information Commissioner’s Office (ICO)’s Age-Appropriate Design Code or relevant geographical code.
- While frameworks and advertising codes may not explicitly mention new and evolving forms of technology, you should consider how they are covered under the principles of existing guidance.
- Consider the potential unintended consequences of age verification such as access to information and privacy. These systems must align with data protection and safeguarding standards.
Principle 4: Agency – Support child users’ decision-making and reduce exploitative features and business models that harm their agency
Recommendations under this principle include:
- Enhance transparency by prominently labelling sponsored or promoted content within product placements, ensuring clear differentiation from authentic, user-generated (organic) content.
- If any content within your advert is AI generated it should be clearly and accessibly labelled so that your target audience can be reasonably expected to understand it.
- Consider the cumulative risk of algorithmic adverts and the constant bombardment of advertising that young people often experience. This can lead to unhealthy consumption habits and exacerbates stress, anxiety, and feelings of inadequacy among young people contributing to mental health issues such as low self-esteem.
Principle 5: Privacy – Embed privacy-by-design and data protection in marketing development and distribution
Recommendations under this principle include:
- Ensure that all children are offered the highest available standards of data protection, in line with UNCRC General Comment 25 and international best practice for data protection.
- Refrain from the profiling or targeting of children of any age for commercial purposes on the basis of a digital record of their actual or inferred characteristics, including group or collective data, targeting by association or affinity profiling.
- AI-created advertising should not infringe on children’s privacy through data collection and use.
Principle 6: Diversity, Equality & Inclusion – Be inclusive, treat everyone fairly and provide for diverse needs and circumstances
Recommendations under this principle include:
- Avoid perpetuating stereotypes or glamourising negative lifestyles in the creation of advertising content or through your ad placement.
- Encourage the representation of diverse perspectives and cultures in advertising content, promoting inclusivity, and helping children develop a broader worldview.
- Use licensed characters and celebrities popular with children with a due sense of responsibility
A total of 40 individuals and organisations participated in the consultation process to gather expert opinions for creating the manifesto. This process included surveys, online and in-person workshops, roundtables, and one-to-one interviews. Thank you to the following organisations and individuals who were involved:
Organisations
- Omnicom Media Group UK
- NSPCC
- Barnardo’s
- SuperAwesome
- Eurochild
- 5Rights Foundation
Individuals
- Andy Burrows, Molly Rose Foundation
- Victoria Ryan, Group Director of Partnerships for The LEGO Group, Initiative
- Paul Wood, Director of Media Standards, Magna Global
- Lexie Kirkconnell-Kawana, Chief Executive, Impress
- Abbi Knell, Programme Manager, Children’s Investment Fund Foundation
- Dr Alexandros Antoniou, Senior Lecturer in Media Law, School of Law, University of Essex
- Dr Karen Middleton, Senior Lecturer, School of Strategy, Marketing and Innovation, University of Portsmouth
- Nicholas Woodford, Content Lead, Anzu
- Laura Lesser, External Communications Lead, CAN Advisory Board
- Dr Francis Rees, The Child Influencer Project, University of Essex
- George Harding-Rolls, Campaign Lead, Action Speaks Louder
- Dr Lisa Sugiura, Associate Professor in Cybercrime and Gender, University of Portsmouth
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