There’s been a great debate recently about what codes of conduct should be in place in terms of marketing at children via the internet.

If your customer base is children, what rules should you bear in mind
to keep your marketing legal and moral? Is it just common sense or is
there more to it?

Marketing Week carried comments from Agnes Nairn, professor of marketing at EM-Lyon Business School in France and RSM Erasmus University in the Netherlands.

She warned that it is very difficult to police online marketing, putting children at risk of advertising and promotions that do not meet the legal requirements in the UK.

Her comments follow calls from Tory leader David Cameron for marketers to show restraint when it comes to selling to youngsters.

Personally, I believe online marketers have a duty to behave responsibly when it comes to kids but if you disagree, I’d be interested to hear why. Perhaps you think the parents need to take overall responsibility or that your only duty is to keep your client within the legal parameters.

Marketing to children online

The ASA enforces rules set out by the Committee of Advertising Practice (CAP) and the Broadcast Committee of Advertising Practice (BCAP).

It’s the CAP code that covers online marketing, so what’s actually in it?

What counts as a child?

The code considers anyone under the age of 16 to be a child but it accepts that that covers a pretty broad range of ages. Some marketing is suitable for teenagers but not for seven-year-olds – that’s pretty clear to most of us.

Don’t cause children harm

Now, even the most hardened salesman is going to raise an eyebrow at this one, after all, you’re unlikely to be selling a product or service that harms your target customers.

However, this actually covers some things you may not have considered. Youngsters shouldn’t be asked to visit strange places or talk to unknown adults – so if you were planning a campaign that encourages them to save labels, wrappers, coupons and so on, you need to be really careful about what you might be encouraging them to do.

On your website or in any marketing messages, be careful not to show children behaving dangerously (unless you’re attempting to illustrate how dangerous it is).

Behaving dangerously could be as simple as being out on the street without adult supervision – depending on the age of the children – so make sure your team is aware of this.

Fair selling to children

I know at least one harassed young dad who thinks it’s never right to market at children. However, children are getting online at younger and younger ages – they’re the so-called ‘digital natives’ – and so more online professionals are being called on to sell to them.

What’s fair and what’s exploitative? Well, the code states that we shouldn’t take advantage of children’s lack of experience, vulnerability, credulity or loyalty. What does that mean in practise?

Self esteem

Don’t try to make children feel inferior or unpopular because they don’t have the product you’re selling. Knowing kids, if it’s a popular product, they’re already making it hard enough for the child that doesn’t have it.


Don’t tell kids they lack loyalty, courage or duty if they fail to buy a product. Children can feel incredible brand loyalty so be careful not to exploit that by making unfair demands, for example, getting them to pressure their friends into buying the product.


Make sure your marketing allows children to judge the size, performance and characteristics of what you’re selling.

The bank of mum and dad

Bit of an obvious one but it’s especially important online. Make sure any child customers get their guardians’ permission before they sign up for any products.

Things to think about

The internet creates a whole new world of potential dangers for kids and online professionals should give this some thought and do what we can to limit the potential harm.

Social media marketers need to give careful thought to any online communities and forums they create; are they safe spaces for children?

Direct marketers need to consider how to prevent young teenagers signing up for inappropriate marketing content – like alcohol adverts.

Banner ads and pay-per-click content needs to be appropriate to kids and conscious of the searches they are more likely to conduct. Adults may search for ‘South Park’ but many kids will too.

Parents, of course, have a responsibility but so do we. Our whole industry needs to work on this problem before a government imposes tough legislation to do it for us.