The following is a summary of AOL’s “Kids Only Channel Policies.” The AAC is obligated to follow these policies at all times. (from “Document Version 2.32”). All items are direct quotes, commentary is in brackets. The original document is 16 pages long. Grammar and spelling are as found in the original document. This document was prepared bu AAC Coord based on policies in effect in July, 1998.
Introduction
AOL developed The the Kids Only Channel Policies (“Policies”) to ensure a uniform consistent set of standards and practices throughout all programming and advertising areas (Rainman or web-based) targeted to kids children 12 and under on America Online, and particularly including through the Kids Only channel. AOL reserves the right to modify these Policies as necessary. Additionally, AOL expects all Partners to abide by the Children’s Advertising Review Board Unit (“CARU”) guidelines for Interactive Electronic Media (see also http://www.bbb.org/advertising/caruguid.html)
Policy PrincipleObjectivesGoals
~Provide a safe, age appropriate environment for kids in a manner appealing to both kids and parents, addressing primary industry and consumer concerns:
~Providing age appropriate content
~Protecting youth privacy, including protection from online predators
~Creating an age-appropriate marketing environment.
~Create a viable programming and business model for youth-targeted areas and partners on AOL.
~Provide a safe, age appropriate environment for kids in a manner appealing to both kids and parents;
~Create a viable programming and business model for youth targeted channels and partners on AOL.
Channel MissionThe Kids Only Channel
The Kids Only channel is the AOL Service’s principal destination for programming targeted to children 12 and under. Kids Only is a “unique AOL, just for kids.” channel. The channel’s mission is to provide a compelling, educational and entertaining interactive media experience for kids 6-12 in a manner appealing to both parents and children. Children’s content may also reside elsewhere on AOL, and is equally subject to Kids Policies compliance. In doing so, to make Kids Only and all programming provided within, a regular, positive part of a kid’s life.
Parental Controls
Since children of all ages use AOL, we’ve created easy-to-use Parental Controls features to help parents ensure their children have a fun and enriching experiences online. AOL Parental Controls allow parents to select one of four basic content and functionality access categories for their child’s screen name. Parents can further tailor their child’s online experience with Custom Controls features. AOL recommends the “Kids Only” category for children 12 and under.
Kids Only screen names have an unique view of the AOL service, with a custom Kids Only Welcome Screen. Kids Only screen names can only visit content areas in the Kids Only channel and on the web, through pre-selected age-appropriate websites. The Internet Solutions Group of The Learning Company selects and manages this list of sites with input from AOL members, partners and The Learning Company’s team of parents and educators. Kids Only screen names have limited access to interactive features such as chat and email, and cannot use Instant Messages while limiting access to some features of AOL and the Internet. These Parental Controls allow parents to designate different levels of access for each child, and to further customize that child’s online experience through Custom Controls offerings.
Child accounts designated through AOL’s Parental Controls provides kids with access to over 10,000 web sites selected by Microsystems Software’s team of parents and teachers for their entertainment and educational value. New web sites are added every month using input from partners and AOL members.
Reach Scope of AOL Kids Only Policies
AOL Kids Policies apply to all “Partner” areas. Partner sites must comply with Kids Policies whether or not the content resides in the Kids Only channel. Policies apply to all entities who provide AOL resident and integrated website content and advertising targeted to kids 12 and under (“Partner”).
“AOL Resident Space Sites” These are either AOL-owned and managed areas OR sites managed by AOL Partners. [The AAC falls in this category.]
AOL Kids Policies Compliance
If AOL becomes aware that a site does not comply with AOL Kids Policies and/or the site has not been approved by The Learning Company: AOL will notify the Partner. The Partner is responsible for taking necessary steps for compliance; the site will not be promoted or linked from AOL Resident Space until it is in compliance; at AOL’s discretion (and as technically feasible) AOL may place a splash screen before the site.
I. CONTENT
A. Content ScopeContent
AOL believes that content targeted to children should be age-appropriate. As such: All content and advertising targeted to kids 12 and under 12 (whether pointed, linked, created, promoted or otherwise integrated; and whether AOL, web-based or downloadable and whether pointed from the Kids Only channel or not) contemplated under the AOL Partner agreement must comply with these AOL Kids policies.
Content should be appropriate and specifically created for children ages 6-12 (not teens, parents or teachers). Links to surcharged content areas are prohibited from AOL Resident Space (including the Kids Only Channel) and Integrated Websites targeting children 12 and under in the Kids only area.
B. Web Content
The web can be an integral part of a child’s online experience. AOL wants to ensure children exploring the web (whether or not they are using a Kids Only screen name) access age appropriate content. As noted in the Parental Controls description above, AOL has enlisted a third party (The Learning Company) to screen for age-appropriate websites for children. Prior to linking or promoting a website, Partners must ensure that The Learning Company approves the site.
C. Newsletter Contents & Distribution
Children look forward to e-mail in the online world as much as they look forward to mail in the offline world. Newsletters can be valuable to children to highlight upcoming online programming that may be of interest to them. However, given the direct contact with the child, it is important to safeguard the child’s privacy.
The primary purpose of a newsletter targeted to children must be for content/editorial programming or online programming promotion only, not for information collection or marketing purposes. All newsletter contents are subject to all policies outlined in this document
Partners may not sell or disclose newsletter subscriber e-mail addresses (or any other identifying information) to third parties. Each newsletter must include information in the text about how a child may “unsubscribe” via e-mail. Partners must comply with all such requests promptly. Newsletter subscriptions must be free of charge and must not require the child to disclose any Individually Identifiable Information to sign-up. Children must be able to subscribe simply by providing their e-mail address.
Newsletters distributed via list-serve must be set up so subscribers cannot individually identify other subscribers to the list-serve. Only the authorized Partner representative (for Partner newsletters) or AOL representative (for AOL newsletters) can send mail to list-serve subscribers. Newsletters are subject to AOL’s bulk e-mail policies (available online at keyword: Junkmail).
D. Online Linking
Online Linking policies are intended to ensure that all content pointed from areas targeted to children is age appropriate, and that Kids Only screen names have equal access to such content.
Sites targeting or residing in areas targeting children may link only to other children’s sites and/or The Learning Company approved websites. Additionally, Kids Only channel Partners may not link to anything outside of the Kids Only channel (children with a Kids Only screen name cannot access areas outside of the channel). Until notified otherwise, AOL Resident Space sites pointed from the Kids Only channel may not use hyperlinks in online areas or e-mail newsletters. AOL’s current Parental Controls technology does not allow Kids Only screen names to access sites hyperlinked within AOL Resident Space. The Kids Only channel must approve all keywords for areas pointed from Kids Only.
II. PRIVACY
Online stores or telephone number promotion of transactions or products are prohibited. No online transactions are allowed in Kids Only, either through a direct link to an online transaction area or through promotion of an online transaction; No product promotions are allowed that promote or encourage children to call a telephone number (including an 800 number) to get product information; These restrictions applyis applies equally to programming and advertising online areas targeted to kids 12 and under.
Information Collection
Any request for personal or other information from children – whether for marketing purposes, contest prize distribution or programming development is prohibited. “Information Collection” is defined as any area request foring personal or other information from kids — whether for marketing purposes, contest prize distribution or programming development.
AOL believes that children can benefit from and should enjoy the interactive nature of the online medium. The online medium makes it easier than ever to communicate directly with a child. While many children are media savvy, AOL believes that young people need special privacy protection online. However, AOL is very concerned about protecting children from inappropriate Information Collection practices. AOL’s long-term goal is to provide parents with a Parental Controls tool to empower them to that allows parents to choose what type of information their child may or may not disclose online. This tool, coupled with appropriate online safety education for to parents and children, this will put the decision-making power and control in the parents’ hands. Until this Parental Controls s technology is available, AOL has created policies that maximize the interactive nature of the online medium and also protects privacy for children and their families. These policies distinguish between two different types of Information Collection, as defined below::
a. Non-Individually Identifiable Information: Personal information about a child that does not in and of itself, or in combination with other information, allow anyone to locate a child offline. The following information combinations are considered Non-Individually Identifiable Information because these combinations do not identify the child or his/her physical location
First name, Age or Birthdate – or –
First name, State – or –
Photo of child, First Name (not screen name) -or –
Screen name (alone, with no other Individually Identifiable Information)
b. Individually Identifiable Information: Personal information about a child that would allow anyone to physically locate a child offline. This includes:
1) any combination of:
First Name
Last Name
School name
Home telephone number
Home address (any part of)
Screen name
Parent’s name(s)
Age or Birthdate (with year) (except with first name)
Social Security Number (not allowed in combination or alone)
2) Singularly any of the following:
Home telephone number
Full name (first, last)
Last name
Address (any part of)
At the point of collection, the area must tell the child (clearly and prominently), if it plans to post or publish online anything the child submits (writings, art, or anything else). Postings are subject to Information Posting policies. The written (postal or fax) parental consent form must specify:
exactly what information the Partner will collect
exactly how the Partner will use this information (particularly if the information will be used for purposes other than online programming or internal marketing) and
Partner contact information so the parent can remit the signed form and contact the Partner if the parent has additional questions. The area must tell the child (clearly and prominently), if it plans to post or publish online anything the child submits (writings, art, or anything else).
Cookies. Partners may not use information transferred through cookie or similar technology for marketing or promotional purposes, sell or disclose this information to any third parties;
Upon AOL’s request, Partner will provide aggregate statistics on these requests and Partner’s processing.
AOL Partners publishing in Rainman must notify the winners via email. If a prize is to be awarded and mailed to the child, the email should follow AOL’s parental notification process, which includes obtaining prior written (fax or mail – not email) parental consent before the prize can be awarded.
Location: Integrated Websites [The AAC will not gather identification information by Website or e-mail form. – HR]
Partners may not disclose or sell collected information from AOL members to third parties in any way that discloses individually identifiable information. Partners may not require kids to register to gain entry to an area or website. The child must be able to participate in the site without providing, through registration or otherwise, personal or other information. Child may not be charged for entry or solicited for a donation. If partner solicitinges art, writings or anything that may be selected for posting/publishing online, this must also be clearly disclosedstated. Kids have copyrights in art, stories, etc. Partners must obtain prior written (not e-mail) parental consent before a child’s submitted work is used or published offline (e.g. a book, magazine reprint) or in any other medium, and for any online uses not previously disclosed at the point of collection.
Partners must remove any Individually Identifiable Information posted by children in Partner’s message boards. This includes removing posts that reveal the child’s first name (since screen name + first name is considered Identifiable Information). Partners should prominently post online safety messages in the message board and other public areas online and educate children not to reveal personal information online.
Chat Areas
Chat is immensely popular with children, and an integral part of the interactive environment. AOL’s policies for children’s chat rooms reflect its concern to protect child privacy.
Partners may not collect or distribute screen names of chat room participants for any reason except to report an online violation or problem;
AOL Resident Space areas must use special “Kids” style chat rooms. These rooms
(a) have no links to chat outside of the children’s targeted space and
(b) link to a special “help” area for children (keyword: kidhelp);
Partners must ensure that there is a Chat Monitor (there as a resource for children, and a “watchdog” for suspicious behavior) present during all open chat room hours. AOL will immediately close any open room found unmonitored. Chat Monitors must:
be at least 18 years of age
be authorized by the AOL Kids Only community manager
pass a background check through an authorized organization
successfully complete training through the AOL Community Leader Organization and are subject to AOL’s monitoring standards for children. AOL will provide training and tools information and schedules;
Partners must open and close chat rooms on a posted schedule — children’s chat rooms cannot remain open 24 hours. AOL will immediately close any rooms found open beyond the scheduled times.
Partners should inform kids of the chat room schedule by prominently posting opening and closing times in the chat entrance. Partners should also inform children how to recognize staff screen names.
The Partner or its Community Leader Coordinator make available to the AOL Community Leader Organization staff screen names and scheduled time slots at least one week before the chat room launches and any time the chat room schedule and/or staffing changes.
AOL reserves the right, in its sole discretion, to prohibit any Chat Monitor from monitoring areas in, or accessible through, the Kids Only Channel.
NOTE: ECR are now available for Kid’s areas.
Message Boards
Message board monitoring is particularly important in areas targeted to children in order to
(a) protect children’s privacy and
(b) ensure the content posted is age-appropriate and free of TOS violations.
All AOL Resident Space sites are required to monitor their message boards (at minimum daily),
(a) answering questions
(b) deleting posts which violate AOL’s Terms of Service (“TOS”) and
(c) deleting posts in which a child has posted Individually Identifiable Information
Message Board monitors (and any other community leaders working in children’s areas) must:
be at least 18 years of age
be authorized by the AOL Kids Only community manager
pass a background check through an authorized organization
Staff screen names must be obvious in message boards.
Partners should discourage adult participation (except for message board monitors) in child-targeted message boards, unless the board is purposely set up for such exchange;
Partners may not solicit contests through message boards. Contest information must be posted in another format. Should children be asked to post any information for a contest on a message board (e.g. a poem or story), none of the information requested may be Individually Identifiable Information.
AOL reserves the right to prohibit staff members from monitoring within Kids Only, if in AOL’s sole discretion, it deems that the staff monitor is harmful to the integrity of or community in the Kids Only area.
Contests:
Those who run contests must also:
Entrance Requirements. The child must be able to enter the contest by simply providing their screen name (e-mail address) on the contest entry form. Partners may not require or ask a child to provide any Individually Identifiable Information for contest entry or at any point without prior parental consent.
Legal Regulations. Partners are responsible for ensuring compliance to any laws regulating contests, lotteries and other games of chance.
Rules & Information. Partners must clearly post and explain rules (in language understandable to a six-year old) on or one link away from the contest form.
Use Partner-created space for posting information and official rules about a contest. Contest rules and information may not be posted on message boards or in chat rooms. Message boards may be a vehicle for contest entries.
Prize Delivery. Adhere to AOL’s requirements for appropriate parental notification and consent for prize delivery:
Partners must notify the winner(s) via e-mail. If a winner either deleted their screen name or has canceled their AOL account, Partner must select an alternate winner.
If a prize is to be awarded and mailed to the child, the Partner must get prior (written) parental consent before collecting home address/telephone information from the child or awarding the prize (see Exhibit B for example).
Obtain written parental permission prior to posting a child’s photo online.
To post a child’s photo, a Partner must obtain prior written permission from the child and his/her parent/guardian. E-mail is not sufficient. Postal Mail or facsimile with signature is.
Providers may use only the following information to “identify” the author when publishing or posting a child’s work or contribution online:
First name, Age – or –
Screen name – or –
First name, State – or –
Photo of child, First Name (not screen name)
Prior to disclosing a first name, a Partner must confirm that no screen name is inadvertently revealed from the functionality used. (For example, organizing a message board folder by screen name but allowing a child to disclose a first name within the posting.)
[AAC policy: use screenname only. – HR]
III. MARKETING
Particularly in the online environment, younger children may not have the developmental capacity to differentiate advertising content from editorial content. For Integrated Websites, AOL requires that any advertising found within thea website area, up to two-clicks away from AOL, must conform to these Kids Only Advertising policies. If any advertisement collects Individually Identifiable Information, AOL reserves the right to remove the link.
a)The entity selling the advertisement is responsible for ensuring it complies with all AOL Kids Policies.
b) The entire advertising site must comply with all policies at time of linking or will be rejected until site complies.
c) The site must continue to comply with policies throughout the term of the agreement. If any advertisement does not comply with AOL Kids Policies after launch, AOL reserves the right to remove the link.
Program personalities, live or animated, should not be used to sell products, premiums or services in or adjacent to programming primarily directed to children in which the same personality or character appears. For example, an ad for Flinstones Vitamins (even if in banner form) may not appear on the same page with Flintstones editorial content. Advertising content must be clearly identified as such in instances where the personality or product is featured in editorial content (e.g. character-driven websites).
The Internet Solutions Group of The Learning Company must approve all web-based advertisements prior to launch. This process requires approximately two weeks. Sites built in Rainman may require a longer production and launch process.
Research
AOL recognizes that research with children is critical to building a viable business, programming and product development. The online environment offers marketers and new product developers an easy way to communicate with children. AOL’s policies are intended to ensure that all research with children is managed responsibly and with the same privacy safeguards that apply to programming and advertising. AOL must authorize all online research. This includes interviews with children online, online research surveys and/or recruiting children online to use in offline studies. Partners should direct all research requests to their AOL Account Manager [through AAC Coord – HR]. If a Partner becomes aware of a third party conducting research online in chat, e-mail or message boards, the Partner should forward this information on to its AOL Account Manager.
Newsletter Contents & Distribution
The primary purpose of a newsletter targeted to children must be for content/editorial programming purposes, and not for information collection or marketing. It can contain no advertising or Internet links. Newsletter subscriptions must be free of charge and must not require the child to disclose any individual personal information other than email address for to sign-up.
Each newsletter must include information in the text about how a child may to “unsubscribe” via email. Partner must comply with all such requests promptly. Newsletters distributed via list-serve must be set up so that subscribers to the list-serve cannot be individually identified by other members and and only the authorized Partner representative (for Partner newsletters) or AOL representative (for AOL newsletters) can send mail to list-serve subscribers. Newsletters are subject to AOL’s bulk email policies.
Online Linking
All Kids Only sites may link only to other AOL Kids Only sites and/or Microsystems approved websites, but not to anything nothing outside of the channel. Areas outside the channel are not accessible to those children with a “Child Access” account designation, and are not approved by the channel.
No Hyperlinking
Our current parental controls technology does not allow children on Child Access accounts to access hyperlinked sites. Until notified of technological feasibility Partners may not use hyperlinks either in online areas or in email newsletters.
Appendix Exhibit A: Microsystems The Learning Company Kids Only Access Site (“Kids Yes-List”) Criteria
Microsystems The Internet Solutions Group of The Learning Company is currently will using the following criteria to include sites on the Kids-Yes list List or “G” rating category. The Kids-Yes List will contain many different Internet resources or “sites” such as web sites, FTP sites, Newsgroups, and gopher sites.
The Kids-Yes Llist will specifically include sites that are believed to be of interest to children from 6-12 years of age and at that reading level. Unless a site is generated by a contracted AOL or Partner Kids Only advertiser, sites that are commercials for the sake of selling a product and only selling a product and have little if any entertainment or educational value will not be added to the Kids-Yes List.
1. Violence/Profanity (graphics or text): The site contains no pictures or text exposing extreme cruelty, physical or emotional acts against any person or animal which are primarily intended to hurt or inflict pain. The site contains no obscene words, phrases, and profanity defined as text that uses, but is not limited to “George Carlin’s 7 censored words” more often than once every 50 messages (Newsgroups) or once a page (web sites).
2. Partial Nudity and Nudity: The site contains no pictures exposing the female breast or full exposure of either male or female buttocks. The site may include swimsuits, including thong swimsuits. Partial nudity of a wholesome nature will be allowed if the publication is like the National Geographic or Smithsonian Magazine. Sites hosted by museums such as Guggenheim, the Louvre, or the Museum of Modern Art may contain partial nudity. The site will not contain pictures exposing any or all portions of the human genitalia.
3. Sexual Acts (graphics or text): The site will not contain pictures or text exposing anyone or anything involved in explicit sexual acts and or lewd and lascivious behavior, including masturbation, copulation , pedophilia, intimacy involving nude or partially nude people in heterosexual, bisexual, lesbian or homosexual encounters. The site excludes phone sex ads, dating services, and adult personals, CD-ROM’s and videos.
4. Gross Depictions (graphic or text): The site will not contain pictures or descriptive text of anyone or anything which are crudely vulgar or grossly deficient in civility or behavior or which show scatological impropriety. Included such depictions as maiming, bloody figures, or indecent depiction of bodily functions.
5. Intolerance (graphics or text): The site will not contain pictures or text advocating prejudice or discrimination against any race, color, national origin, religion, disability or handicap, gender, or sexual orientation. Any picture or text that elevates one group over another will not be allowed. The site will not contain any intolerant jokes or slurs.
6. Satanic/Cult: The site will not contain pictures or text advocating devil worship, an affinity for evil, or wickedness. The site contains no advocacy to join a cult. A cult is defined as a closed society that is headed by a single individual where loyalty is demanded and leaving is punishable.
7. Drugs/Drug Culture: The site contains no pictures or text advocating the illegal use of drugs for entertainment. The site contains no substances used for other than their primary purpose to alter the individual’s state of mind, such as glue sniffing.
8. Militant/Extremist: Site contains no pictures or text advocating extremely aggressive and combative behaviors, or advocacy of unlawful political measures. Excluded topics include groups that advocate violence as a means to achieve their goals. Sites contain no “how to” information on weapons making, ammunition making or the making or use of pyrotechnics materials. Site contains no use of weapons for unlawful reasons.
9. Questionable/Illegal & Gambling (graphics and text): Site contains no pictures or text advocating materials or activities of a dubious nature which may be illegal in any or all jurisdictions, such as illegal business schemes, chain letters, copyright infringement, computer hacking, phreaking (using someone’s phone lines without permission) and software piracy. Site contains no text advocating gambling relating to lotteries, casinos, betting, numbers games, on-line sports or financial betting, including non-monetary dares.
10. Alcohol or Tobacco (graphics or text): The Site will not contain pictures or text advocating the sale, consumption, or production of alcoholic beverages and tobacco products.
Exhibit B: E-mail Notification to Child & Parental Consent Form Example
Congratulations [child’s screen name]! You have been selected as the prize winner in the [name of online area, name of contest]! In order for you to receive your prize, you must print this e-mail and give it to your parents. Your parents must complete the information on the Parental Consent Form, indicate their approval by signing it and mail or fax it back to us. If we do not receive this form completed and signed by [specific date], we will choose an alternate winner:
[Form available from AOL. – HR]