We have a new crop of workers beginning to emerge and with them comes a whole new set of rules we need to follow. But are they even on your radar? Meet the 'generational new kids on the block:' Generation Z - a population of 23 million and counting who began coming of age in 2013. Raised by protective "Gen X" parents, this emerging workforce is growing up in an extremely diverse environment and takes "digital native" to a whole new level. They've got an ease with technology that will benefit business greatly as we continue to make strides in social marketing, data analytics, and connected living - they've been connected in one form or another all of their lives. As such, connecting with them on social becomes a chief concern and initiative for Talent Attraction marketers. Snapchat strategies are explored, Instagram and Vine contests are cooked up in the hopes compelling User Generated Content can be found and used.

Is Social Engagement w/ Gen Z Safe?

Before you engage with the younger generation, it's important to ensure that you're in compliance with FTC (Federal Trade Commission) guidelines, as well as individual platform guidelines for marketing. Even if what your organization is advertising is employment, it's still advertising - especially when part of your "talent attraction" efforts include giveaways and prizes for joining your "talent network," "talent community," or any other cute term you've come up with for your employment communication list. That activity is clearly subject to COPPA (Children's Online Privacy Protection Act), the oversight of which is managed by the FTC. Enacted in 1998, there was an amendment to the rule that took effect in July of 2013 - the intent of COPPA is to put parents in control over what information is collected from their young children online - specifically, kids 13 and younger. If you just honed in on the "13" and thought, "Wait a minute! This doesn't apply to us because we're advertising to teens who are of legal age to work" - you aren't alone - but that's also not really the point. Even if your intended target is 14, 15, or 16 (depending on your organization's and state's minimum work age requirements); there's still important consideration to make sure you cover:

• Age Verification- before allowing someone to sign up for your talent network, ensure they are over the minimum working age and not subject to COPPA restrictions. This can be done with a simple yes/no radial dial question or having prospective candidates enter their birthdate as part of the sign-up process... done before any personal information is submitted. Personal information covered by COPPA include:
  • First and last name;
  • A home or other physical address including street name and name of a city or town;
  • Online contact information;
  • A screen or user name that functions as online contact information;
  • A telephone number;
  • A social security number;
  • A persistent identifier that can be used to recognize a user over time and across different websites or online services;
  • A photograph, video, or audio file, where such file contains a child’s image or voice;
  • Geolocation information sufficient to identify street name and name of a city or town; or
  • Information concerning the child or the parents of that child that the operator collects online from the child and combines with an identifier described above.

• Communication Guidelines - ensure you state a minimum age in your contest guidelines and if soliciting User-Generated Content, ensure it's within COPPA guidelines by requiring all people within an image to be over the age of 13. If they are not, then you must notify parents and obtain verifiable parental consent before collecting (much less reusing) personal information – including photos and screen names that could be used to directly contact users online (think tweets, pins, facebook messages, etc).

This means for most of our "working purposes," communication with most of Gen Z is perfectly acceptable. Although often we are targeting adults over the age of consent, and legal working age is over 13 - it still doesn't mean that these rules aren't something we should be mindful of. Disclosing data collection practices, while becoming more common, is still something many employers have yet to do in their talent attraction effort. As part of the research for this article, 40 companies that employ minors were visited; less than half a dozen had proper disclosures and clearly stated minimum age requirements for engagement. This is problem because we still clearly benefit from the information we collect from candidates - and as such, there is a punitive potential for our organizations when we fail to follow laws put in place for the protection of our youth. We need to seek first to better understand this grey area and put a plan in place allowing us to act in accordance with FTC guidelines, as well as clear guidelines/communication strategies designed for each age group. Finally, all campaigns that have a UGC component should be vetted through legal, especiallyif you employ minors, to ensure your social media plan is legal.   In the next post, we'll look at communication strategies and popular platforms for Gen Z.