That is one of two key recommendations the groups made in a letter being sent today to the White House, Justice Department, Commerce Department, and the co-chairs of the Interagency Subcommittee on Privacy and Internet Policy of the White House's National Science and Technology Council.
The groups, which include the Center for Digital Democracy (CDD), Consumer Federation of America, Children Now, Benton Foundation, and the American Academy of Pediatrics, said they want the administration to recommend passage of new legislation that "protects adolescent privacy." The letter follows up a meeting they had last month with members of the subcommittee.
"[T]eenagers are key targets in a rapidly growing online marketplace that subjects them to increasing amounts of data collection, behavioral profiling, and manipulative techniques that threaten their privacy," the groups wrote. "Because the needs and capacities of young people are distinctly different from those of adults, we call on the Interagency Subcommittee and the White House to incorporate into the forthcoming White Paper a policy framework that addresses the privacy concerns of both children and adolescents."
There is already a law protecting the online privacy of kids 13 and under (the Children's Online Privacy Protection Act [COPPA]), but the groups say that rather than trying to apply the parental consent mechanism in COPPA to teens, new legislation should be crafted to provide a separate set of fair information practices applying to marketers to target teens and requiring user-friendly privacy policies and an opt-in regime for their data collection so they will not be "subjected to behavioral profiling and tracking" without their "informed, prior consent."
One of their arguments for stepping in to protect kids up to 18 years old is that teens are in the thrall of biological urges of particular intensity that make them more susceptible to digital marketing, "especially when they are distracted, are in a state of high arousal, or are subjected to peer pressure [editor's note: which is just about all the time]."
The FTC is preparing to make recommendations for updates to COPPA, and the groups want them to strengthen that law by applying its privacy protections to mobile devices, online gaming sites and other platforms not addressed in the 1998 law.
The green paper totally ignored the needs of kids and adolescents, says Jeff Chester of CDD. "We expect the Obama administration to play a key leadership role. It now has an opportunity in the forthcoming white paper to strongly endorse new safeguards for America's youth." Chester has been in the vanguard of those warning that online privacy and targeted marketing, particularly of kids, would be the next big media battleground.
Also signing on to the letter were the American Academy of Child and Adolescent Psychiatry, Center for Science in the Public Interest, Consumer Action, Consumer Watchdog, National Consumers League, Privacy Rights Clearinghouse, Public Health Law and Policy, and the World Privacy Forum.