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CTR June 2018
Vol. 30 No. 6 Issue 220

Download this issue as a PDF
Legal rights of children; Echo Kids; Six Types of Scratch Projects
“Animals had legal rights before children.” Learn more about the history of children’s rights,

As a reviewer of children’s interactive media with a background in child development, I frequently stumble upon bad behavior in some of the products I review. It’s easy to find examples. Some are promoted heavily to children in the largest app stores. My Tamagotchi Forever is one of many examples

Why are these experiences harmful? They are specifically designed to trick a child for financial gain. They mix cute animals with BF Skinner’s operating conditioning, Natasha Dow Schüll’s ludic loop and Mihály Csíkszentmihályi’s flow state. They call these techniques “onboarding” and “leveling” to create just enough “friction” to get children to buy something.

But they’re free. Why is this bad? Like weeds, these types of experiences choke out the ethical publishers like Toca Boca, Tinybop and Nosy Crow by using a child’s device storage, battery power and bandwidth. They also waste something more valuable -- play time. In the USA, these experiences are largely unregulated and undocumented, and they fly beneath COPPA requirements.

What should be done? App stores who sell products for children should do a better job disclosing the actual costs of all experiences, as defined as the total possible amount of money an app might be able to collect. In  My Tamagotchi Forever, it is possible to spend $99 in real dollars in a single transaction, in order to unlock the full app. These costs are fuzzy and hard to define. Secondly, app stores should make it easier for teachers, librarians and parents to find “ethical” apps. These are experiences that are free of commercial motives, and that are transparent about all costs and commercial content, before the purchase point. In the meantime, we’ll do our part by flagging this behavior as frequently as possible.

We were happy to leadership in the area of children’s data collection from the ICO (Information Commissioners Office) from England. The GDPR, or General Data Protection Regulation) is from an independent government group designed to set up to and uphold information rights. The USA (and USA app sellers) would do well to study this concept. Read more at

At a glance:
• Children need particular protection when you are collecting and processing their personal data because they may be less aware of the risks involved.
• If you process children’s personal data then you should think about the need to protect them from the outset, and design your systems and processes with this in mind.
• Compliance with the data protection principles and in particular fairness should be central to all your processing of children’s personal data.
• You need to have a lawful basis for processing a child’s personal data. Consent is one possible lawful basis for processing, but it is not the only option. Sometimes using an alternative basis is more appropriate and provides better protection for the child.
• If you are relying on consent as your lawful basis for processing, when offering an online service directly to a child, in the UK only children aged 13 or over are able provide their own consent.
• For children under this age you need to get consent from whoever holds parental responsibility for the child - unless the online service you offer is a preventive or counselling service.
• Children merit specific protection when you use their personal data for marketing purposes or creating personality or user profiles.
• You should not usually make decisions based solely on automated processing about children if this will have a legal or similarly significant effect on them.
• You should write clear privacy notices for children so that they are able to understand what will happen to their personal data, and what rights they have.
• Children have the same rights as adults over their personal data. These include the rights to access their personal data; request rectification; object to processing and have their personal data erased.
• An individual’s right to erasure is particularly relevant if they gave their consent to processing when they were a child.

“Almost all the ed-tech applications do not clearly define safeguards taken to protect child/student information, and do not support encryption, or lack a detailed privacy policy.”

The May 24, 2018 called 2018 State of EdTech Privacy Report (by Girard Kelly and Jeff Graham) at found things like advertising within the context of displaying content and behavioral ads based on the child’s usage of the service.

“Among web-based services, 37 percent indicate that collected information can be used by tracking technologies and third-party advertisers, 21 percent indicate the collected data may be used to track visitors after they leave the site, and 30 percent ignore “do not track” requests or other mechanisms to opt out.”

What happens to a child’s personal information? “Nearly three-fourths (74 percent) indicate they maintain the right to transfer any personal information they collect if the company is acquired, merged, or files for bankruptcy.” Read the Edweek summary, at

What’s new is Scratch? We go straight to the source to make sure we’re See page three.

Here’s an undisputed fact. The next generation will grow up in a world with smart speakers. Amazon’s new Echo Kids (on this month’s cover) is one of the first mainstream speakers to target children specifically. What do you need to know? These devices represent a convergence of three software technologies: 

ASR = Automatic Speech Recognition
NLP = Natural Language Processing
AI = Artificial Intelligence
ML = Machine Learning.

Why the difference in the cost between the regular Dot and the Kids Edition? It's the one year of access to the audio content that is part of Amazon's "FreeTime Unlimited." This includes 300 Audible books for kids, like Beauty & the Beast and Peter Pan, thousands of songs, and kid-favorite games and COPPA compliant kid skills from Disney, National Geographic and Nickelodeon. “Kid skills” are skills that have been identified by the developer as directed to children under age 13.

Kids love the voice interface, and use it for all kinds of things -- especially playing music, asking questions, and setting timers. If you have several Echos on the same Wi-Fi network, you can set them up as an in-house intercom.

Parents can review activity, set limits at bedtime, filter explicit songs from Amazon Music and toggle off voice shopping. The kids version comes with more positive interaction style that includes "please" and "thank you."

The bundle comes with 1 year of Amazon FreeTime Unlimited. After one year, your subscription will automatically renew every month, with prices that start at $2.99/month plus tax. So if you use your Amazon Echo Kids for 10 years, you will have invested about $530.

Learn more by listening to a talk given by Martin Farrows, COO Soapbox Labs, a Dublin publisher that specializes in voice driven products for children, at