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A Day in the Life as a CARU Intern

Each semester, CARU hosts an intern. This summer semester, Jessica A, a law student, joined the CARU staff. Here is some insight into a day in the life of a CARU intern, written by our intern herself.

My first assignment as an intern at CARU was to evaluate a certain mobile app that is directed at children for compliance with COPPA and CARU’s self-regulatory program (the Guidelines). I was instructed by one of the staff attorneys to begin by reading the app’s privacy policy to learn about its data collection practices. After the app successfully downloaded and I was excited to get started, I was bombarded by in-app advertisements. Then, gameplay led me to realize that while the app was free to download, the “catch” was that the free version offered limited features. There existed heavy sales pressure to unlock additional features via pop-ups for in-app purchases. As I sat tapping away on the phone’s touchscreen, I received curious glances from NAD staff members who might easily have assumed I was unprofessionally texting or tweeting on the job!
The above describes one of many exciting responsibilities of a CARU intern. Interns and staff attorneys alike monitor apps, websites, television commercials, print ads, and other advertisements for compliance with CARU’s Guidelines as well as federal laws such as COPPA. CARU aims to help advertisers and website operators bring their designs into compliance before they subject themselves to fines imposed by the FTC but more importantly, before children’s inherent vulnerabilities can be exploited.
Throughout the summer, I have learned that the CARU staff engages in routine monitoring and much more. The CARU staff also runs the first FTC-approved COPPA safe harbor program, records and archives case reports, pioneers research on issues related to children’s media, and presents conferences that bring together the key players in the industry. For example, in anticipation of the July 1st date of the FTC’s COPPA Rule Amendments coming into effect, CARU brought together its Supporters to discuss the Amendments (including the Amendments’ effect on the future of online behavioral advertising). As an intern, it was exciting to be in the same room with general counsels and representatives of major children’s television networks and toy companies as well as leading privacy and advertising lawyers and other great minds. The '90s child within me wanted to run up to some of these people and blurt out how much I loved growing up with their programming and products! I also wanted to tell them how I still sometimes watch “kid’s TV” and peruse toy stores when I feel nostalgic (hey, don’t pass judgment, I am sure you sometimes linger on the kid’s networks when flipping through channels!).
In sum, CARU is awesome and it has been a pleasure to intern here! I have learned about industry self-regulation and children’s media law whilst conducting legal research and writing. With the FTC’s COPPA Rule Amendments newly in effect, the office’s excited air is contagious. The staff is busy guiding and advising their safe harbor participants as well as engaging in routine monitoring. My summer internship has provided me with an invaluable experience. I leave here with a different outlook on commercials, websites and apps geared towards children. I now can’t help asking myself - is that character wearing a helmet while riding that bike? Is that family eating excessive amounts of food contrary to normal portion sizes? Is that product being advertised labeled ‘Keep out of reach of children’? Does this website need to obtain verifiable parental consent?
I thank the entire CARU staff for the amazing opportunity to join them this summer and look forward to seeing more of the amazing work that CARU does.

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