"Gates" as scandals probably started with Watergate but many other embarrassments followed suit with a similar gating moniker. Nipple-gate or Janet Jackson's Superbowl wardrobe malfunction, Zoe Baird's Nanny-gate are just a few. Age-gating your website to make sure it is COPPA-compliant should not give rise to messy press and finger-pointing. Web designers and marketers need to remember that kids are smart and make reasonable efforts to thwart their efforts to evade your controls. A few recent CARU cases are instructive.
The Harlem Globetrotters advertised a world tour in Boy's Life and Sports Illustrated Kids, both child-directed publications, and sent readers to HarlemGlobetrotters.com for show dates and tickets. The tour itself, of course, is family-friendly, and new jokers have replaced our generation's Meadowlark Lemon, Wilt Chamberlain, and Curly Neal. The site also includes a tab labeled "Kids Games Here!" and also allowed visitors to enter PII to sign up for an e-newsletter. Underneath the sign up was a checkbox "You are 13 or older." CARU suggested the Globetrotters modify the age-gate in a way that was more neutral to discourage a fake out by kids seeking to avoid parental permission requirements.
Fantage.com operates a virtual world where kids can choose an avatar, customize it and then play and socialize. When a visitor enters the site, he or she needs to register with a username and password. The next question is "How Old Are You?" followed by a drop down menu with numbers from 3 to 80. If the registrant selects 13 or older, the site prompts for an email address. If 12 or under is picked, the field changes to request a parent/guardian email. Registrants could use the back button to return to the age question and select a higher number and then be asked for their own email. CARU expressed concern that the website did not employ a tracking mechanism such as session cookies to prevent kids from easily opting for a do-over and circumventing the age-screening. Fantage agreed to make changes.
So the bottom line is when setting up an age-gating mechanism on your website, make sure it asks questions about age in an open-end and neutral way and has safeguards in place to avoid kids from simply using the back button for a do-over to gain entry to a site.
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