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Newsletter: Stop Targeted Advertising to Kids | December update

Dear Global Action Plan Supporter

Welcome to our regular campaign newsletter, which aims to reflect on the harms of consumerism, update you on the latest news of internet regulation and draw on the connections between these two topics in how we reduce advertising to children, while recognising that challenging advertising to kids can advance the aims of a wide range of campaigners. 

UK online harms proposals


An image of You Tube

On 15 December, the UK government *finally* published its proposals for regulating online harms. These proposals will form the basis of draft legislation that we’re promised next year, though so far we’ve not been told when. 


Ofcom has been formally appointed as regulator, with specific responsibility for a ‘Duty of Care’ on social media companies. Online companies will become legally responsible for the harm suffered by their users, and failure to comply with this Duty of Care will result in – we’re told – fines of up to £18m or 10% of global turnover, whichever is higher. This latter figure could be eye-wateringly large for companies like Facebook and Google. 


What constitutes an online harm will be set out in broad terms in the legislation, with certain specific harms – likely terrorism and child sexual exploitation and abuse related, codes of practice regarding which have also been published – to follow some way down the line in secondary legislation. 


The online harms agenda has always been about specific, well-known harms, and the appropriate way to legislate them. Advertising to children as a harm in itself has not featured in this debate. Clearly concern about the harms of marketing to children is lower among policy makers and, bluntly, the public. But as anyone who has watched The Social Dilemma will understand, ad revenue is the end goal for online companies and all the strategies to keep users engaged are geared towards it. The data generated by ads and users’ engagement with them enables the microtargeting upon which more obvious ‘harms’ rely. 


Put simply, there is not a single online harm – from polarisation, disinformation, and the automated promotion of harmful content – that is not more worrisome because of microtargeting. Turning off behavioural advertising would see demand for tracking and microtargeting dry up, to the benefit of all internet users. Campaigners engaging with the online harms legislation (and pre-legislative scrutiny) would be well served to foreground these arguments. 


EU weighs in


Wednesday also saw publication of two other very significant developments re regulation of the internet. The European Commission published the text for the Digital Services Act (DSA) and the Digital Market Act (DMA), which are intended to be mutually reinforcing. 


This excellent summary outlines what the two Acts are intended to do (and when – spoiler: not soon) including details of specific moves in the DSA with regards to online advertising. Put simply, big tech firms will be required to provide “greater transparency to people over who targets them with online ads and how”. This from the European Commission’s Q&A about the DSA is instructive: 


“[Users] will have to be clearly informed whether and why they are targeted by each ad and who paid for the ad; they should also see very clearly when content is sponsored or organically posted on a platform…” 

“[very large online platforms] will have to maintain and provide access to ad repositories, allowing researchers, civil society and authorities to inspect how ads were displayed and how they were targeted. They will also need to assess whether and how their advertising systems are manipulated, and take measures to mitigate these risks” 


While not necessarily preventing the targeting of ads to children, these new rules will allow campaigners to much better understand what has previously been a completely opaque process, with only the platforms themselves being privy to precisely who is being targeted and why. 


YouTube and gambling

In yet more proof that the video giant can act when it feels like it, YouTube has announced that it is going to give users the option of turning off ads (including contextual ads) for booze and gambling.  


Perhaps one day YouTube will move beyond its current line that YouTube “isn’t for kids” and therefore ads targeted at kids isn’t a problem on its platform.  



Ads for green groups find climate denial


In news that might make a few green groups sit up and take notice, it’s emerged that climate denial sites are raking in cash from adverts for green groups. As per previous efforts to defund hate sites, the advertisers almost certainly have no idea that their content is being placed on these problematic sites. Yet more evidence of how utterly broken online advertising is, and the urgent need for reform. 


Advertising and the environment

While there has been much fanfare in the UK about new targets for emissions cuts out to 2030, there has been little attention on the yawning gap between *existing* targets and progress towards meeting them. The UN has, however, published its annual emissions gap report. Perhaps the biggest takeaway is that the richest 1% of world’s earners are consuming way, way more than is compatible with a 1.5 degree pathway. This graph sums it up best. 


There is still far too little attention paid to how we get the rich world’s consumption patterns heading down, fast. Constantly pummelling people with ads to buy more and more stuff cannot be part of the solution. 


Best wishes,

Ollie and the Global Action Plan Team