• PrivCom Bermuda

Guest Post: "Behavioural Ads Are Bad for Kids"

Ariel Fox Johnson, of Common Sense Media, writes that it is "common sense" to keep kids' data off-limits and to change the business model that uses behavioural advertising. Ms. Johnson will participate in an event with our office on June 8th - for more details, see our recent blog post.

We have all learned that "free" comes at a price - often, to our privacy. For years, the costs of apps and services have been subsidized by their users' information, feeding an ad-supported model that tracks and profiles all of us, including children and teens. We are categorized and labeled ("Working-class Mom," "The Awkward Years - High School Students," "Rich Kids of America"), and then manipulated and microtargeted with the ads and content that companies believe relevant.


Indeed, researchers recently discovered Facebook would let them target teens labeled as "interested in gambling" with ads featuring poker chips and dice. Other equally disturbing ads could be purchased to target teens interested in alcohol, smoking, or extreme weight loss.


Big tech companies have convinced advertisers and marketers that the more targeted the ads are, the better, but this business model's underlying profitability for most companies is questionable. More traditional "contextual" ads, which are displayed based on a website or app's content and not on who is visiting it, may be nearly as profitable and much less controversial.


The behavioral ad model has underappreciated costs, especially for kids. In Common Sense’s recent explainer, we examine the practice of behaviourally targeted advertising, the harms it poses for young people, and what policymakers and companies can do to improve the landscape.


Behaviourally targeted ads are now standard fare for online platforms, and they have become very big business. But the truth is, behaviourally targeted ads are bad for kids.

  • Kids do not want targeted ads. Most kids and parents are uncomfortable with the idea that their data is being used for targeted advertising.

  • Kids do understand how their information is collected, analyzed, and used by commercial actors, and they are largely defenseless against such targeting techniques.

  • Behavioural profiling is particularly problematic for kids because it happens at a unique time of development -- when both their brains and identities are developing and forming. Historically, this is precisely when society has encouraged children to explore new things and not worry about making mistakes.

Common Sense believes that children and teens should not be tracked and profiled online, or subject to behavioural ads based on their personal information or online activity. And we are supportive of global efforts to achieve this goal, undertaken by regulators, legislators, and companies themselves. We believe everyone can work together, for example by:

Given growing agreement that the status quo is not working for kids and families, we look forward to new movement on this issue.


In the meantime, check out other resources for parents and families from Common Sense:

Ariel Fox Johnson is Senior Counsel for Global Policy at Common Sense Media, where she advocates for smart practices, policies, and rules to help all kids thrive in today’s wired world. Her work focuses on enhancing family privacy rights, strengthening students' educational privacy, and promoting robust consumer protections in the online world. She frequently advises policymakers, industry, and tech experts, and has helped develop laws on student privacy, consumer privacy, and the Internet of Things. Ariel is a graduate of Harvard College and Law School. Prior to joining Common Sense, Ariel worked on privacy, media, intellectual property, and technology matters at corporate law firms, and provided pro bono assistance to nonprofits and asylum seekers.

To reach out to the Office of the Privacy Commissioner, please visit our Contact Us page.

Press Background:

  • Rights and responsibilities relating to data privacy are set out in the Personal Information Protection Act 2016 (PIPA). Bermuda's PIPA received Royal Assent on 27 July 2016. Sections relating to the appointment of the Privacy Commissioner were enacted on 2 December 2016, including the creation of the Office as well as those duties and powers relevant to its operation in the period leading up to the implementation of the whole Act. The Commissioner works to facilitate the advancement of consequential amendments to other Acts in order to harmonise them with PIPA.

  • The Office of the Privacy Commissioner for Bermuda (PrivCom) is an independent supervisory authority established in accordance with the Personal Information Protection Act 2016 (PIPA).

  • The mandate of the Privacy Commissioner is to regulate the use of personal information by organisations in a manner which recognizes both the need to protect the rights of individuals in relation to their personal information and the need for organisations to use personal information for legitimate purposes, among other duties.

  • The Privacy Commissioner's powers and responsibilities include monitoring the processing of personal information by both private- and public-sector organisations, investigating compliance with PIPA, issue guidance and recommendations, liaise with other enforcement agencies, and advise on policies and legislation that affect privacy. PrivCom also works to raise awareness and educate the public about privacy risks, and to protect people’s rights and freedoms when their personal data is used. The general powers of the Privacy Commissioner are outlined in Article 29 of PIPA.

  • Alexander White (Privacy Commissioner) was appointed by Excellency the Governor, after consultation with the Premier and Opposition Leader, to take office on 20 January 2020.

  • Privacy is the right of an individual to be left alone and in control of information about oneself. In addition to the protections in PIPA, the right to privacy or private life is enshrined in the United Nations' Universal Declaration of Human Rights (Article 12) and the European Convention of Human Rights (Article 8).

  • "Personal information" or data is a defined term in PIPA that means any information about an identified or identifiable individual. Examples include names, dates of birth, photographs, video footage, email addresses and telephone numbers. "Sensitive personal information" is a defined term in PIPA that includes information relating to such aspects as place of origin, race, colour, sex, sexual life, health, disabilities, religious beliefs, and biometric and genetic information. (Note: This is not a complete list.)

  • "Use" of personal information is a defined term in PIPA that means "carrying out any operation on personal information, including collecting, obtaining, recording, holding, storing, organising, adapting, altering, retrieving, transferring, consulting, disclosing, disseminating or otherwise making available, combining, blocking, erasing or destroying it."

  • About Common Sense Media: Common Sense describes itself as "an independent voice for kids, families, and communities everywhere. We combine original research with game-changing advocacy efforts to make the digital world work better for all kids. Our advocacy work highlights legislation related to technology and identifies solutions that protect consumer privacy, push for better connectivity for students and families, and hold tech companies accountable to ensure a healthy internet for all." More information may be found at their website.