Mobile Marketing to Children

In an article in the London Times today it was reported that junk food firms face a ban on targeting children on their mobile phones. Read more...

The concern over marketing to children as a means to combat the growing obesity problem in the UK comes at a time when there is an increasing attention to what constitutes best practice guidelines that relate to marketing to children in general - but also specifically when it comes to marketing to children via the mobile.

Best Practice Guidelines

The MMA-UK has a specific section regarding marketing to children in their Code of Conduct. There are specific guidelines on what you can and cannot do based on age.

The DMA UK has recently released their best practice guidelines for mobile marketing - missing the section on marketing to children. That section has been under review for some months now and the DMA is looking to harmonize their overall code for marketing to children and including mobile as a direct marketing channel. The DMA’s current Code of Practice covers marketing to children with specific references to Online Marketing.

Within the UK, different jurisdictions have defined children as anything from under 12 to under 18. Some research provides for age groupings of 7-10 years of age and 11-14 – Children 15 and up are sometimes considered to be young adults where restrictions are typically related to adult content, tobacco and alcohol.

As today's youth market is increasingly mobile enabled, there is a significant amount of attention and investment being made by brands in reaching these consumers via their mobile phones. It is encouraging to see the marketing community recognizing the opportunity and the need for respecting the end consumer - in this case a child.

What about mobile TV?

As mobile technology advances, the mobile phone is capable of more than just talking and sending the odd text message - it is a rich multi-media device. Consumers are spending a growing percentage of time looking at their phones, watching the screens, compared with the percent of time they spend with their phones glued to their ears in deep and meaningful conversation (like your nail polish colour...) And with this new media rich device comes a more interactive and rich Internet experience - the mobile web as well as streaming and broadcast mobile TV.

Whether it is WAP pages with banner ads or Mobile TV from Sky - these are services that the mobile phone user requests and then consumes personally via their mobile phone. There is no requirement for permission because the consumer is requesting the content. (i.e.; it is not an unscheduled/unsolicited message that just turns up). And there may or may not have been any traditional marketing involved in raising awareness of the availability of the service. But even with no requirement for an explicit permission, there may be a case for requiring age verification.

Age verification systems are already in place to help restrict adult/objectionable content from the prying eyes and fingers of minors. With trends such as we see from the Times article above, age verification could be required for mobile marketing of any product targeted at children including marketing of junk foods.

No wait a minute - kids that young don't have mobile phones!

Well - that's what I'd like to think. But I'm a single 40 year old with no kids. For those of you who are parents - you tell me. When did you child first start pestering you for their very own mobile phone? When did most of Johnny and Susie's classmates start turning up for play dates fully equipped with their own mobiles?

A recent Mobile Youth report shows that consumers as young as 11 are starting to have mobile phones and in 2004 the majority of growth was from children aged 5-10. The primary driver being for children having these mobile phones was the parents who wanted to have contact with their children – rather than the kids asking for the phones on their own. As they say, everything at a price. You can have better access to your children by giving them a mobile phone - from which the children can access all kinds of mobile content.

Where does "mobile marketing" begin?

Because mobile marketing (at least in the UK/EU) requires a consumer's opt-in prior to first contact, I would propose that a majority of mobile marketing actually begins with the traditional marketing effort and if there are any regulations, it should be certain to include direct marketing to children via traditional channels.

If a brand is going to promote themselves via on-pack promotions then it should not include a mobile response mechanic and/or mobile based incentive if the marketing is targeted to children under a specific age.

If the marketing is so broad that the reach is towards both children and young adults, it should be made clear in the creative that only young adults and adults above a certain age are eligible to participate. The mobile mechanic should then have a built-in age verification step to ensure compliance.

In the recent flap over the Crazy Frog ringtone, the Advertising Standards Authority stepped in and required Jamster to restrict their advertising to the post-9PM watershed hour to restrict the impact on children. (Read more…) This was marketing of a mobile content service that was arguably targeted at children that were too young to understand the terms and conditions of the subscription service they were signing up to. It wasn’t necessarily mobile marketing – but it certainly was content that was delivered via the mobile.

If, as marketers we take care in creating our marketing campaigns to ensure that any mobile component or mobile channel is sensitive to the age of the participant, we're on the right track. And if in doubt, we can refer to the DMA or MMA codes of practice on marketing to children.