Finnish lessons for mobile marketing to kids

By Mickey Alam Khan

May 8, 2008

A Finn-tastic experience

WASHINGTON – Can U.S. mobile marketers learn anything from Finnish efforts to protect children as mobile phone users?

Finland is arguably one of the most advanced mobile markets worldwide, having let its consumers buy soft drinks using a phone at a vending machine early in the decade. The country’s attorney at Kuluttaja – the Finnish consumer agency and consumer ombudsman – quickly got to the point at the Federal Trade Commission’s mobile event.

“Direct marketing to children under 15 is not allowed without parental consent,” Riitta Kokko-Herrala told delegates yesterday at the FTC’s “Beyond Voice: Mapping the Mobile Marketplace” event. “Direct marketing to children under 10 via mobile violates the law.”

Mobile phones in Finland are used to pay for interactive television and Internet games as well as buying logos and ringtones. That is fine as long as the buying consumer is an adult, but not a minor.

“The basic problem is that in Finland the industry doesn’t provide the means to recognize the contracted party as minors,” Ms. Kokko-Herrala said.

As a result, the consumer agency has taken several actions to prepare children as users.

First, the agency is focusing on consumer education. There is information available on the agency’s Web site for parents, education materials for schools and complaint forms for consumers addressed to wireless carriers and service providers.

The agency also works on cooperation with carriers. It released a pocket guide for subscription sellers and also made sure that carriers help consumers with the right contact information.

In addition to these measures, the agency has developed guidelines on marketing and selling mobile content as well as the guidelines on SMS bans applicable to certain mobile initiatives.

Ms. Kokko-Herrala gave the example of Case Habbohotel, a virtual hangout popular with teens online and mobile. Consumers can buy services through SMS messages and charged to the mobile phone.

The firm implemented best practices, so the consumer agency received only a few complaints.

What helped was clear guidelines: children under 10 were not allowed to sign in and minors under 15 need parental consent. Plus, there was a balance limit of 10 euros per player per week.

Now contrast that with some ambiguity in according accountability for actions related to mobile commerce. A 12-year-old boy ran up a 3,000 euros bill on his mobile phone. The parents balked at paying. The carrier said the parents handed the kid the word.

What the Finnish consumer disputes came back with was that the kid wasn’t competent enough to enter into an agreement with the seller. So his parents weren’t liable for his actions and were not asked to pay the carrier.

It did seem obvious from the audience questions that marketing to kids over mobile was a serious concern. A panelist quickly shot down the suggestion that the Finnish ban on mobile marketing to kids under 10 could work in the United States.

Another audience member suggested a registry similar to the Federal Communications Commission’s Do Not Call list for mobile phones used by kids. Ms. Kokko-Herrala said Norway already had a similar registry in operation.