Namah Bose, Devesh Khandelwal
I. Introduction
The news of Tiffany Smith, mother of famous teen YouTube star Piper Rockelle, getting sued for $22 million by 11 teen content creators who featured on Pipers channel, for emotional and sexual abuse brought the plight of young influencers to the forefront.[1] The 2022 case is among several instances wherein influencers have reached courts with allegations of abuse during content creation. Influencers are online content creators who advertise products and services and possess a strong influence on the purchasing decisions of their audience.[2] By the end of 2023, influencer marketing is expected to be worth more than $21 billion.[3] With more than 75% of brands dedicating part of their budget to influencer marketing,[4] becoming an influencer is one of the most lucrative career options.
Kids with significantly sizable social media followings on platforms like YouTube and Instagram are referred to as child social media influencers or “kidfluencers”, a portmanteau of the words kid and influencers.[5] The most successful of these ‘kidfluencers’ can make more than $20 million a year in revenue.[6] Generally, the accounts of ‘kidfluencers’ are created and maintained by their parents because the majority of social media platforms including Facebook, Instagram, and YouTube require users to be at least 13 years old to register their account.[7] The current regulatory framework be that Information Technology Act, 2000 or other regulations fail to adequately address the legal and ethical implications of influencers under 18.
Although they are not legally recognized as such, ‘kidfluencers’ are effectively a digital era equivalent to child actors since they make money through sponsored material and/or the monetization policies of social media sites. Child actors are at a grave risk of exploitation from producers and hence, laws have been framed to ensure their legal rights. The lack of recognition of online content creation by these children on an equal footing with that of child actors often leads to exploitation. The need to address key issues relevant to kidfluencers, including privacy concerns and possible exploitation issues has been acknowledged globally.[8]
The pertinent question that this new era of “influencing and kidfluencers” raises is whether these children are actively employed or if their online presence is merely a matter of personal expression. The general justification on the part of parents and guardians is that they “intend to only capture their child’s day-to-day activities, instead of a rehearsed performance.”[9] But even when parents don’t intend to harm their kids, the exorbitant fame and money from ‘influencing’ may hamper the growth and development of these children.[10]
The essay aims to tackle the legal complexities that may arise out of ‘kidfluencing’ and suggest the manner in which states should regulate online activities to ensure that children are not overworked in the name of ‘influencing’. It is divided into four parts – Firstly, analyzing existing definitions if any and discussing probable definitions for ‘kidfluencers’. Secondly, examining the distinct challenges faced by ‘kidfluencers’ in the influencer market. Thirdly, determining whether the existing regulatory framework in India is sufficient to protect ‘kidfluencers’. Lastly, the essay intends to provide recommendations that can be adopted by India as well as other states to ensure that children working in the influencer market are protected and the role of social media platforms can play towards safeguarding the best interests of children.
II. ‘Kidfluencers’- need for comprehensive definition
The only official definitions of influencers in India are provided in the “Endorsement know-how” guidelines of the Department of Consumer Affairs and ASCI guidelines for influencer advertising in digital media.[11] The definitions are from the perspective of consumer protection, as they focus on the disclosure of material connection with the advertised product and do not address child influencers. The lack of a specific definition of child influencers remains unaddressed and reflects the gap in the current legislative framework. It potentially leaves child influencers unprotected from financial and mental exploitation, without their rights recognised. Getting the definition of child influencers right is especially pertinent as it will influence the ease of adoption and implementation of any regulatory and protective mechanism that may be put in place to safeguard the rights of child influencers.
Recently, an attempt was made by Illinois state to include kidfluencers under its regulation through a specific definition.[12] The Illinois law applies to individuals or families that create sponsored videos for use on online platforms. Under the definition, the content should contain the name, photograph, or likeness of a minor under the age of 16, and should fulfill certain criteria regarding the presence of the minor in the sponsored content and minimum number of views required which is included in the definition for child influencers for the Illinois laws to apply.
In 2020, France enacted a kidfluencer law that provides a workable framework for a regulatory mechanism.[13] France through its new law expanded the definition of ‘child entertainers’ and updated it to include children who “work for an employer who makes audiovisual recordings of minors under the age of sixteen with intent to distribute the recordings on social media sites.” The Child and Adolescent Labour (Prohibition and Regulation) Act (CALPRA), 1986 defines a ‘child artist’ in India.[14] While in Indian context merely expanding ‘child artist’ definition will not adequately protect the interests of child influencers as the legislation as a whole does not envisage the digital influencers industry, which has its unique challenges. However, India can use the French law as a reference for formulating specific regulation.
III. Examining Challenges faced by ‘Kidfluencers’ – Beyond the glamour
The United Nations (U.N.) Convention on the Rights of the Child (hereinafter ‘CRC’) is an international human rights treaty that sets out the civil, political, social, economic, health, and cultural rights of children.[15] While this international agreement was adopted pre-social media, the core principles of this treaty can be relied upon as a guide for developing and enforcing protections for monetized Kidfluencers whose online presence is run by their parents. To understand the role played by CRC in setting the principles in stone for the protection of children, one needs to analyse the kind of challenges faced by ‘Kidfluencers’. Three broad challenges come to light and they are –
1. Privacy and Mental Harm concerns
An analogy can be made between reality television stars and ‘Kidfluencers’, both of whom live their lives publicly. Similar to the plight of reality TV Stars, who are both exposed to humiliation, hate comments and bullying, kidfluencers grow up amidst constant online engagement. Unlike reality TV which lasts for a couple of months, such children spend their formative years exposed to online harassment. Receiving such noxious communication may hamper the mental health and personality development of such children. Studies have shown that a child’s personality and temperament develop even within the first five years of life. It highlights the probable damage due to constant content creation on kidfluencers.
The content recorded by families and such influencers often display private moments of a child’s life which may amount to a breach of privacy. Several testimonies of children who have grown up with families creating social media content includes them having gone as far as changing their legal name so as to disassociate with the content created in their childhood.[16] The ‘right to be forgotten’ is an essential element that can aid kidfluencers in removing content uploaded by their guardians or by themselves at a later stage in life. The European Union established the right in 2014 as a consequence of an ECJ ruling.[17] Art. 3 of the CRC talks about the ‘best interests principle’ by which any institution, guardians, government, and other bodies that make decisions for a child or children collectively, are required to keep the best interests of such child/children in their mind. Yet, it can be seen that parents, in a bid to monetise their children, make decisions on behalf of children without regards to their best interests.
Further, social media’s dark underbelly goes beyond mere breaches of privacy and online harassment, as platforms like Instagram have been found to be fuelling dangerous pedophile networks.[18] Wall Street Journal through a test study found that Instagram algorithm geared overly sexualized child content to accounts that solely followed preteen girls, cheerleaders and displayed an interest in children.[19] Art. 19 of the CRC states that children should not be ill-treated, or exploited and should be kept away from physical and mental violence. However, the wall street study indicates that the instagram algorithm is helping connect pedophiles and creating a demand for such exploitative content.
2. Impediment of Education
The US Supreme Court in Pierce v. Society of Sisters (1925), recognized that parents are free “to direct the upbringing and education of children under their control” without state interference.[20] But we could look at the treatment of student-athletes and student actors to understand the need for state requirement of educational protection in the kidfluencer industry because of the parallels of profit-making at the cost of formal education. In India, the CALPRA law allows kid artists to work on the condition that the child must not be engaged in any work that is likely to interfere with his or her education.[21] Children whose parents choose the influencer life for them, may end up sacrificing their time for formal education and healthy social interactions to the influencer life just as child actors do,[22] even after legislative protections.Today, Kidfluencers are at an even greater risk due to the blurry lines separating their work time with their personal life.
3. Financial Protection
Art. 32 of the convention deals with child labor and economic exploitation.[23]However, the creation of content by children can turn into economic exploitation as they often earn significantly. It has been recognized through research that videos featuring a child under 13 years old receive three times as many views as those without children.[24] One prominent example is Ryan from Ryan ToysReview, who at 7 years old, was the highest-paid YouTube Influencer, earning $22 million.[25] At the price of their privacy and after exerting hours of labor, these children generate significant revenue for their parents, while having no legal protections and no guarantees that they will ever see this money.
A parent’s decision to make their child an influencer can have serious long-term financial effects, as it is often at the cost of excelling in school or developing other skills. Furthermore, ‘kidfluencers’ are not considered child artists, so they do not receive the same protections. A similar scenario existed for child actors before the Jackie Coogan case, which led to the enactment of the Coogan law by California in 1939.[26] Coogan Law federal equivalent puts a requirement that the parent or guardian of the child actor must set up a blocked trust account for the child, into which 15% of the minor’s acting wages are deposited until the child turns 18 years old.[27] Today’s child influencers must also get to enjoy the fruits of their labor and all of the profit sharing should not end up with the parents, sponsors, and platforms. Internationally, Illinois took the first step in this direction and formulated a law to ensure that ‘kidfluencer’ are entitled to a percentage of the revenue based on the frequency of their appearance in a video and the views garnered.[28]
IV. ‘kidfluencers’ from the Indian lens
Anantya Anand, Nihal Raj, Varchasvi Sharma, Prajakta Padhi – all have something in common, they are all under 15 years of age and have a massive fan following on social media platforms. Indian child social media influencers, ‘kidfluencers’ have jumped on the bandwagon of influencing and are talking in millions. Yet, when one thinks of these influencers, one thinks of a glamorous lifestyle filled with fame and money. Nobody considers the dark aspects of influencer culture involving stretched working hours, discontinuation of education or financial exploitation. Which brings us to an imperative question – Are ‘kidfluencers’ protected in India against the various challenges mentioned in the essay?
The answer is a complex and convoluted one, as due to the lack of a singular regulatory framework expressly recognizing ‘kidfluencers’, one needs to look at multiple laws and conventions. Different challenges faced by them would require us to look at different laws.
The two primary legislations available to protect children from labor exploitation – the Factories Act, 1948, dealt with hazardous employment and the Child Labour [Prohibition and Regulation] Act, 1986, permitted children employed in the entertainment industry. It was later seen that child artists were underprotected under the legislative framework. CALPRA was brought in place to protect child artists working on sets by providing a statutory framework for specified working hours, registration of child artists with authorities and compensation of education through private tutors.
The National Commission for Protection of Child Rights (NCPCR) drafted guidelines for child and adolescent participation in the entertainment industry replacing the 2011 guidelines.[29] The guidelines are thorough and exhaustive taking into consideration several aspects for ensuring the best interests of children are being maintained. The only critique of the NCPCR guidelines is the lack of proper implementation protocols. The guidelines for child actors employed on sets state that no child should be made to work more than 5 hours in a day and never more than 3 hours without rest.[30] It is easy to monitor whether such a protocol is being followed in a traditional set-up for a movie or show. But, whether a 5-hour requisite is being met while recording for online content creation is hard to determine as such a shooting takes place within the confines of a child’s home. Chapter 3, dealing specifically with children employed for creating online content, states that a child or adolescent cannot be employed for content creation during school hours and between 7 P.M. and 8 A.M.[31] However, monitoring such a requirement is a mammoth task, and prima facie it can be easily said that the content created by children and adolescents mostly violates this provision of a fixed timeframe.
Similarly, a provision has been made to ensure that the parent, guardian, or family would make an account in a nationalized bank for a child/adolescent earning profits from such online content and would ensure that 20% of such wages are invested in a fixed deposit scheme. The provision is well thought out and ensures that on attaining the majority, child social media influencers have a safety net of their income to depend upon. Monitoring Authorities should ensure compliance with this provision by the guardians of the kidfluencers.
The provisions present for children employed for the shooting of any film and movie require prior approval from the district magistrate. [32] While logistical difficulties will be faced for the same provision for creating social media content, a digital equivalent needs to be created. Currently, online content is being created without the knowledge of the district magistrate, NCPCR, or the SCPCR. The guidelines have bestowed certain duties on the social media platforms in addition to the duties on such online media platforms given by the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021.[33] A social media platform has to ensure that users are aware of the laws and guidelines, and that content should not be posted in violation of the present regulatory framework. While Social media platforms should definitely be given certain tasks with regards to monitoring and reporting, placing the entire regulatory burden on such platforms might create conflicts with national laws as the platform is not a government entity. Also, such a platform lacks power to ensure that all the provisions regarding timings and wages are being complied with by the adult. The guidelines attempt to provide for periodic inspections by an inspector at the venues of employment where it is hazardous, nevertheless, no similar form of inspection of whether such conditions are met by online creators has been included. The lack of an inspecting authority makes it difficult to detect violations of the NCPCR Guidelines. Various authorities like NCPCR and the DM have been made responsible for the implementation of the guidelines, but a simple question as to how they are to conduct checks on child social media content creators has not been answered. The guidelines, thus, are like a toothless snake, rendering the envisioned safeguards ineffective. They manage to cover those employed in the traditional entertainment industry consisting of films and shows but fail when it comes to regulating online content creation.
The responsibility of ensuring that children creating content are not exploited by their families and not overworked is tricky work. It becomes all the more difficult to ensure that such violations of a child’s best interests do not take place when the entire family is a part of the influencer community.
While the government can play a central role in regulating the manner in which ‘kidfluencers’ or content creators function, the intermediary platforms including Facebook, Instagram and TikTok can also play certain key roles in protecting the rights of children. The NCPCR guidelines have provisions that deal with the nature of content created, are a step in the right direction. Social media platforms can ensure that the content created by children is not obscene, or pornographic and are consistent with the laws. However, for other instances the intermediaries are given protections from liabilities through the ‘Safe Harbour’ provisions in the IT Act, 2000. [34]India and the United Kingdom follow the principle of conditional liability by which intermediaries are protected from any liability for posts/information by users of the platform, based on fulfilment of certain criteria mentioned within the provisions. Under the IT Act as per Sec. 79 that talks about intermediary liability, it is stated that intermediaries have the responsibility to remove and disable unlawful content, once they are aware of its existence. Further, the intermediaries are to follow all additional guidelines if any provided by the government. If such provisions are ignored, the intermediaries lose the safe harbour and become liable for content posted by third parties.
The information technology (intermediary guidelines and digital media ethics code), Rules 2021 were additionally released to provide a framework for working of social media intermediaries (SMI). Under these rules, the government has bestowed certain powers on social media platforms to ensure content displayed is not harmful to children amongst other objectives.[35] For example, it gives the power to SMI’s to remove and flag content that is considered obscene. However, it means that the SMI’s will be given the right to determine what is considered objectionable. It brings us to the free speech, right of expression and differential approach to morality debate. Considering that some of the popular SMI’s are not based or founded in India, the allegations of westernised approaches towards content moderation can also occur in the instance.
While the onus of incurring responsibility to monitor content created by ‘kidfluencers’ can be partly bestowed on such platforms, the pros and cons of allowing intermediaries to make decisions can lead to them becoming increasingly selective. Understanding which content created by children could be harmful or could be perceived as obscene, could also lead to a chilling effect on freedom of speech and expression. Thus it is necessary that guidelines and directions for intermediaries be drafted after giving consideration to freedom of speech and expression. It is pertinent to note here that, while the study by Wall Street journal has noted that children are sexualised through the algorithmic patterns of platforms like Instagram, removing content created by pre-teens and adolescents stating that they violate guidelines could become problematic as well. The balanced approach, thus, would not be to shift the entire burden on intermediaries, but rather work with them to ensure that algorithms aren’t geared towards favouring pedophiles, parents/guardians to be made aware of NCPCR guidelines while uploading videos etc. Further, responsibility can be given to intermediaries to inform authorities when content created repeatedly violates guidelines and can be deemed to be harmful for children.
V. Recommendations and Solutions
It is clear that ‘Kidfluencing’ and the epidemic of monetization of children can turn into a modern-day menace impacting the lives of many children unless regulated. A blanket ban on ‘kidfluencers’ would be counterproductive and rather the immediate recommendation would be to create a regulatory framework that allows children to act as influencers without the burden of challenges. Such a regulatory framework would not just depend on the government but rather on all the stakeholders involved including guardians, schools, monitoring authorities, parliaments that draft legislations, and the social media platforms i.e intermediaries.
The saying ‘Charity begins at home and justice next door’ becomes applicable as guardians can educate themselves about the negative consequences of displaying children excessively on social media and can also educate their children who use such platforms. Awareness among guardians on the NCPCR guidelines can go a long way to ensure that ‘kidfluencers’ are not exploited. The glaring problem within these guidelines is the lack of monitoring authorities that can ensure the implementation of the guidelines. Similar to producers requiring to register the children employed on sets of their feature films, a law can be created through which influencers regularly uploading content of their children or guardians of children under 13 that create content may be required to register in a one-time manner before a monitoring authority. An innovative probable solution can be entrusting an authority like the child welfare committees with being the collector of data under whom such kidfluencers need to be registered. The powers of the child welfare committees, constituted in every district in India can be broadened/ expanded to include maintaining data of such influencers. A newly established central authority can regulate the functioning of the state and district level authorities like the CWC’s. Information regarding such content being created would aid the government in understanding the extent and number of ‘kidfluencers’. Similar to the national survey of India, policies for kidfluencers can be drafted better once statistics are publicly known.
Social media platforms would play an imperative role in ensuring that content cannot be uploaded by children without receiving proof of registration. The government can mandate platforms to flag and remove content of children uploaded by their guardians if they have not complied with the registration requirement. This responsibility can be given by updating the IT (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021. The provision can be interpreted to be broad enough to necessitate the monitoring, and even removal of exploitative content concerning kidfluencers, by the order of appropriate authorities or voluntarily by the social media platforms. Intermediaries can be asked to ensure close cooperation with authorities tasked with monitoring kidfluencers and family influencers creating content. Freedom of speech and expression needs to be balanced with rights for children envisaged by Indian laws.
While, the practical implementation remains doubtful as the ability of social media platforms to undertake such task is questionable. This is in light of the fact that the platforms have even been unable to flag graphic content successfully.[36] The repeated failure to successfully filter and remove graphic content due to the sheer amount of content being created also leads to another question, are intermediaries capable of taking the additional burden of monitoring and regulating kidfluencers.
A step that can be taken by Intermediaries is that they can successfully create awareness of NCPCR Guidelines and its existence to guardians through the platform. Monitoring authorities along with social media platforms can be given the task of regularly checking the content uploaded by Family influencers and ‘Kidfluencers’ to confirm that the NCPCR guidelines are being followed in reality. Unless a monitoring authority is aware of ‘kidfluencers’ in a particular region, an expectation of them discovering glaring violations would be redundant.
Furthermore, immediate attention by authorities and social media platforms is required to ensure that guidelines such as at least 20% of earnings by such children must remain in trust for them until they reach adulthood are being implemented. Internationally, Illinois took the first step in this direction and formulated a law to ensure that ‘kidfluencer’ are entitled to a percentage of the revenue based on the frequency of their appearance in a video and the views garnered.[37]
It is essential to understand that the growth of social media at an unprecedented rate has left the laws lagging behind every new development. Governments need to grapple with innovative ways to ensure that children are not negatively impacted by the influencer culture. The digital landscape should not turn into an anarchical environment wherein children are economically exploited in the name of content creation.
[1] Meredith Clark, ‘Who Is Piper Rockelle’s Mother? What We Know about Tiffany Smith Abuse Allegations’ THE INDEPENDENT (Apr 17 2023, 21:52 P.M) https://www.independent.co.uk/life-style/piper-rockelle-mother-tiffany-smith-lawsuit-b2321405.html.
[2] Merriam-Webster. (n.d.). Influencer. In Merriam-Webster Dictionary. https://www.merriam-webster.com/dictionary/influencer (accessed March 26, 2024).
[3] Werner Geyser, ‘The State of Influencer Marketing 2023: Benchmark Report’ INFLUENCER MARKETING HUB, (Oct, 30 2023) https://influencermarketinghub.com/influencer-marketing-benchmark-report/.
[4] Fine F. Leung, ‘Does Influencer Marketing Really Pay Off?’ (24 November 2022) HARVARD BUSINESS REVIEW, https://hbr.org/2022/11/does-influencer-marketing-really-pay-off.
[5] Matthew Reddin, ‘ACCC report highlights concerns around the kidfluencer culture’ THE BIG SMOKE (10 May 2023) https://thebigsmoke.com.au/2023/05/10/accc-report-highlights-concerns-around-kidfluencer-culture/.
[6] Tyler Cowen, ‘Kidfluencers are the chimney sweeps of the information age’, MINT, (5 October 2023) https://www.livemint.com/opinion/online-views/kidfluencers-are-the-chimney-sweeps-of-the-information-age-11696505497626.html.
[7] Digital, Culture, Media and Sports Committee, Influencer culture: Lights, camera, inaction? (HC 2021-22, 41).
[8] Australian Competition and Consumer Commission (ACCC), Digital Platform Services Inquiry—March 2023 Interim Report (Australian Competition and Consumer Commission, 2023), https://www.accc.gov.au/about-us/publications/serial-publications/digital-platform-services-inquiry-2020-25-reports/digital-platform-services-inquiry-march-2023-interim-report; UK Parliament Committees. Government Response to the Influence of Influencers Report (2023). https://committees.parliament.uk/work/1126/influencer-culture/.
[9] Id.
[10] Rachel Greenspan, ‘TikTok is breeding a new batch of child stars. Psychologists say what comes next won’t be pretty’ INSIDER, (9 July 2020) https://www.insider.com/psychologists-say-social-media-fame-may-harm-child-star-influencers-2020-5
[11] Department of Consumer Affairs. Endorsement Know-Hows. https://consumeraffairs.nic.in/sites/default/files/filefield_paths/Endorsement_Know-Hows.pdf.
[12] 820 ILCS 205/0.5, 205/2.6, 205/9, 205/12.6 (1782 State Bar Edition)
[13] France, Law No. 2020-1266 of Oct. 19, 2020, visant à encadrer l’exploitation commerciale de l’image d’enfants de moins de seize ans sur les plateformes en ligne, Journal Officiel de la République Française (Oct. 20, 2020).
[14] India, Child Labour (Prohibition and Regulation) Amendment Act § 3, No. 35 of 2016 (July 29, 2016).
[15] Convention on the Rights of the Child, (adopted 20 November 1989) 1577 U.N.T.S. 3 (CRC).
[16] Latifi, F. Influencer Parents and Their Children Are Rethinking Growing Up On Social Media. Teen Vogue. TEEN VOGUE, (Mar 22, 2023) https://www.teenvogue.com/story/influencer-parents-children-social-media-impact
[17] Case C-131/12, Google Spain SL v. Agencia Española de Protección de Datos, EU:C:2014:317.
[18] Lois M. Collins, (2023, November 27). Instagram reels show sexualized content of children, Wall Street Journal study says. DESERET NEWS ( Nov 27, 2023 1:00 P.M) https://www.deseret.com/2023/11/27/23977820/instagram-reels-toxic-sexualize-children-ads-brands-wall-street-journal-study
[19] Jeff Horowitz, ‘Instagram’s algorithm delivers toxic video mix to adults who follow children’ (Wall street Journal, 27 November 2023) <https://www.wsj.com/tech/meta-instagram-video-algorithm-children-adult-sexual-content-72874155 > accessed 1 December 2023.
[20] Pierce v. Soc’y of Sisters – 268 U.S. 510, 45 S. Ct. 571 (1925)
[21] Sec. 3, The Child Labour (Prohibition and Regulation) Amendment Act 2016, No. 35 of 2016 (IND)
[22] Mrityunjay Bose, Child artists in films and TV work for over 12 hours a day: Study, DECCAN HERALD, (4 January 2024). https://www.deccanherald.com/elections/child-artists-in-films-and-tv-work-for-over-12-hours-a-day-study-1116656.html
[23] Convention on the Rights of the Child, art. 32 (adopted 20 November 1989) 1577 U.N.T.S. 3 (CRC)
[24] Patrick Van Kessel and others, ‘[2. Children’s content, content featuring children and video games were among the most-viewed videos genres]’, in ‘A Week in the Life of Popular YouTube Channels’ (Pew Research Center, 25 July 2019) <https://www.pewresearch.org/internet/2019/07/25/childrens-content-content-featuring-children-and-video-games-were-among-the-most-viewed-videos-genres/> accessed 28 December 2023.
[25] Madeline Berg, ‘How This 7-Year-Old Made $22 Million Playing With Toys’ (Forbes, 3 December 2018) <https://www.forbes.com/sites/maddieberg/2018/12/03/how-this-seven-year-old-made-22-million-playing-with-toys-2/?sh=5f0dad844459> accessed 1 December 2023.
[26] CAL. FAM. CODE § 6752 (West 2020)
[27] Fair Labor Standards Act of 1938, as amended, 29 U.S.C. §§ 201–219 (2023)
[28] 820 ILCS 205/2.6, 205/12.6 (1782 State Bar Edition)
[29] Goswami, Madhushree, ‘NCPCR guidelines to protect child actors in flims OTT’, The quint, May 27, 2023, accessed November 29, 2023, https://www.thequint.com/explainers/ncpcr-guidelines-to-protect-child-actors-in-films-ott.
[30] Ministry of Information and Broadcasting, Government of India, Guidelines for Child and Adolescent Participation in the Entertainment Industry and Any Commercial Entertainment Activity, PDF document: https://mib.gov.in/sites/default/files/Guidelines%20NCPCR.pdf. .
[31] Id
[32] The Child Labour (Prohibition and Regulation) Amendment Act, 2016, No. 35, Acts of Parliament, 2016 (India).
[33] Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021, Ministry of Electronics and Information Technology, Government of India, https://www.meity.gov.in/content/information-technology-intermediary-guidelines-and-digital-media-ethics-code-rules-2021.
[34] Information Technology Act, 2000, § 79, No. 21, Acts of Parliament, 2000 (India).
[35] Rule 3(1)(b) of the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021.
[36] Nyce, Caroline, “Should you delete your kid’s TikTok this week,” The Atlantic, October 11, 2023, accessed January 3, 2024, https://www.theatlantic.com/technology/archive/2023/10/graphic-content-children-social-media-use/675619/.
[37] 820 ILCS 205/2.6, 205/12.6 (1782 State Bar Edition)