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Children’s Commercial Media Literacy: New Evidence Relevant to UK Policy Making Regarding GDPR


Like all EU member states, the UK has until May 2018 to implement the General Data Protection Regulation (GDPR) into UK law. Article 8 states that, unless Member States decide otherwise, children under the age of 16 must have parental permission to use “information society services”, which are related to most online resources. Most of the provisions of the GDPR are designed to improve the protection of personal data for the general public. Some provisions specifically concern the additional protection of children in view of their supposedly lower media literacy. Sonia Livingstone, LSE and Kjartan Ólafsson, University of Akureyri, present their analysis of Ofcom data to examine whether this age limit makes sense. A footnoted version of the report with more details on the data and methodology can be found here.

At present, little or no evidence of children’s vulnerability or their parents’ ability to protect them is cited in both the UK and European GDPR debates. This brief report examines whether and how age has an impact on levels of media literacy, particularly commercial (or advertising) literacy, which has long been theorized to gradually increase in childhood and early adolescence. We take note of the recent affirmation of the International Chamber of Commerce to protect children under the age of 13 from undue commercial pressure (see also the US COPPA) and the recent European research showing that children are exposed to such pressures.

New analysis based on Ofcom data on media usage and attitudes

To assist the UK in making this decision, we conducted an exploratory analysis of the following survey data:

  • Ofcom’s 2016 media usage and attitudes of children and parents dataset (children 5-15; adults with a child 3-15 living at home for whom they have parental responsibility)

We looked at media literacy issues related to the Internet, focusing on the commercial and critical dimensions of literacy.

Business education indicators in all age groups

As the following graphic shows:

  • The commercial competence of children increases quite steadily from 8 years to young adulthood. In particular, they are gradually becoming less likely to believe that all information on news media websites is true (blue line) and are more likely to know that sponsored results on Google are ads that have been paid to be there.
  • Basic commercial training has improved noticeably from 13 to 16. This could support the intent of Article 8 of the GDPR that individuals under the age of 16 deserve parental protection. Or it reflects the advantages of the UK computer curriculum so that if UK schoolchildren used to teach business literacy, 13-year-olds could learn that older teenagers learn, eliminating the need for parental protection for younger teenagers.


Note that Ofcom also asked if children thought all the information on social media sites was true, but only 2% of 8-11 year olds and 4% of 12-15 year olds agreed – less than in 2015 and less than adults also the respondents from the 2015 survey.

In terms of confidence in Google search results, the graph below shows the results for search engine users ages 8-21. This suggests:

  • As children grow older, they acquire the basic business education to recognize that some, but not all, search engine results can be trusted. However, there is not a large increase in understanding by the early teens; the main win is with younger children.
  • On this basis, one could conclude that 13-year-olds are almost as educated as 16-year-olds (these are younger internet users with a lack of business skills).

sonia-kjarten-figure-2The next graph shows the same data for the entire adult age range and shows the following:

  • Both younger and older people have a slightly lower level of critical digital competence compared to the 30 to 60 year olds.
  • The gains through adolescence continue into the late 20s with no apparent limit to commercial education by the age of 16.
  • It is also noteworthy that around a third of adult internet users believe that all Google results are trustworthy. This indicates the need for greater transparency through search engines and / or better digital literacy for all adults, not just children.


Business education indicators for 12-15 year olds

Ofcom asks children and adults if they know how media are funded as an indicator of commercial education. The following graphic shows answers for YouTube and Google:

  • This graphic indicates a significant increase in the commercial competence of children between the ages of 12 and 15 years.
  • Interestingly, the responses for Google suggest that 14- and 15-year-olds have greater literacy rates than older teens and young adults.

sonia-kjarten-figure-4It’s worth noting that combining children’s data with data from adults from all age groups gives little confidence that business literacy will continue to increase with age or that parents have the knowledge to keep their children safe. As a matter of fact, the majority of UK adults (including many parents) do not know how Google is funded.

Finally, using questions only asked 12-15 year olds, Ofcom’s data suggests that children by age 15 have a greater degree of business education compared to what they know by age 12 or 13 as shown below. The following graphic shows this:

  • From 12 to 15, the children’s commercial competence increases significantly as they learn that advertising is personally targeted (blue line) and vloggers are paid to promote products (orange line).
  • The graphic also shows, albeit less clearly, that 12 to 15 children tend to appreciate “like” information on the Internet and that personal data is more likely to be made available in order to gain “followers”.
  • So it is by no means clear that a critical understanding of the digital environment leads to cautious behavior with regard to the protection of personal data.

sonia-kjarten-figure-6What can we conclude from this?

The intent of the GDPR is to reduce children’s vulnerability to commercial and data risks. By and large, commercial media literacy increases among teenagers between the ages of 12 and 15 (although not necessarily much more after that). This suggests that parental consent up to the age of 16 would have privacy and data protection benefits.

  • In other words, since the evidence suggests that children become increasingly media literate as they age, experience, and maturity, it can be concluded that at a younger age they should rightly be protected by parents and regulation.
  • However, the older children get, the less effective it is to establish rules that prevent them from accessing social networks. The requirement for parental consent could therefore lead to both increased deception and evasion on the part of young people and potentially inequalities in who can or cannot obtain parental consent.
  • Alternatively, it could be argued that the results at hand show the benefits of school media education for older adolescents and, if they were extended more systematically to younger children, would protect their privacy from commercial exploitation even without parental supervision.
  • In short, the observed gap in business education between the ages of 13 and 16 could be closed by more and better media education in school for all children, certainly from the age of 11 (ready for 13), if not earlier, so that they can learn the critical Skills required to protect yourself in a commercial environment.
  • Fair treatment of children by companies should also be effective in helping them understand, at a young age, how online services are funded, how their data is treated, and the choices and remedies available to them.

Viewed in this way, the available data measure the size of the gap to be filled in order to bring 13-year-olds to the knowledge of 16-year-olds (and ideally the knowledge of the entire population of currently insufficient knowledge about the economic environment and the conditions of online data processing ).

If, to the likely horror of teenagers, the UK chooses 16 instead of 13 as the age for parental consent to children’s Internet use, the likely cost of teenagers’ reduced opportunities for creative, educational, civic and communicative activities online would also be important.

As always, children’s rights to online protection must be viewed in the light of their rights of provision and participation in order to resolve potential legal conflicts and to pursue their best interests as a whole.

This post reflects the views of the author and does not represent the position of the blog of the LSE Media Policy Project or the London School of Economics and Political Science. A footnoted version of the report with more details on the data and methodology can be found here.


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