The Mix
"The Mix is the UK's leading support service for young people."
They offer help services from 11-25.
So children as young as 11 year olds need to trust them
If not younger as their website is available publicly without age gates.
This article is about these children being encouraged to give marketing consent for advertisers to track their problems.
And about how data is shared anyway.
A note about consent
Consent under data protection law is not appropriate for younger children, especially under 13s and in circumstances where a child cannot be expected to seek their parents involvement to either give consent for them or help understand the risks.
For all children, under UK law, their best interests must be considered when organisations share their data, regardless of consent.
Feeling suicial? This website uses cookies
Let's take the suicide page as an example, the one you would hope they care the most about.
They claim
"The Mix is an anonymous service for young people and we do not routinely collect personal details or health data in our services except in safeguarding interventions via our 121 helpline services or when young people are working directly with our counsellors; this is only done with young people’s consent, held securely for a time limited period and not passed to outside agencies."
However, they state regarding their request for consent for their marketing cookies
"We use cookies to personalise content and ads, to provide social media features and to analyse our traffic. We also share information about your use of our site with our social media, advertising and analytics partners who may combine it with other information that you’ve provided to them or that they’ve collected from your use of their services."
"Marketing cookies are used to track visitors across websites. The intention is to display ads that are relevant and engaging for the individual user and thereby more valuable for publishers and third party advertisers."
You cannot personalise and be anonymous, so which of the above is the truth?
The Mix share your data anyway
Whilst the cookie banner is showing on the screen, The Mix's website has already sent data to advertising companies.
The following is a request to Twitter, it's a bit complicated
It's also very easy to spot "mental-health" and "suicide" in the request.
https://syndication.twitter.com/srv/timeline-profile/screen-name/themixuk?dnt=false&embedId=twitter-widget-0&features=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%3D%3D&frame=false&hideBorder=false&hideFooter=false&hideHeader=false&hideScrollBar=false&lang=en&maxHeight=600px&origin=https%3A%2F%2Fwww.themix.org.uk%2Fmental-health%2Fsuicide&sessionId=0a2b96989cd522f0879c84706096b90b949d9540&showHeader=true&showReplies=false&transparent=false&widgetsVersion=01917f4d1d4cb%3A1696883169554
Unless you have blocked cookies, this will send an ad personalisation id to Twitter and if you have been logged into Twitter, it will send your user cookies too.
Will "suicide" and "mental health" now be topics that Twitter uses to recommend content and ads to you?
Media IQ
An ad company who "Deliver ad campaigns that redefine marketing success."
https://pixel.mediaiqdigital.com/pixel?u1=https://www.themix.org.uk/mental-health/suicide&pixel_id=[pixel_id]&uid=6389831442458291536
I'm guessing this is MIQ
In which case, if you read their privacy policy it forbids the usage of their pixel regarding health, sex life, sex orientation, religion, race, under 16s, gambling and many other topics The Mix support.
Microsoft (xandr / AppNexus / adnxs)
Acquired a couple of years ago, xandr will "Reach audiences across screens with premium advertising"
https://secure.adnxs.com/px?id=933481&seg=10898761&redir=https%3A%2F%2Fpixel.mediaiqdigital.com%2Fpixel%3Fu1%3Dhttps%3A%2F%2Fwww.themix.org.uk%2Fmental-health%2Fsuicide%26pixel_id%3D[pixel_id]%26uid%3D%24%7BUID%7D&t=2
The adnxs domain uses user tracking cookies..
If you wish to reach an audience of suicidal kids to improve sales of your alcoholic beverages, pain killers and anything else that might sell well, perhaps this company has the data to serve your needs.
Google Analytics
https://region1.google-analytics.com/g/collect?v=2&tid=G-W6H1MZLKKG>m=45je3ai0&_p=2063492146&gdid=dMWZhNz&cid=895917720.1697748142&ul=en-gb&sr=1920x1080&lps=1&_s=2&sid=1697750078&sct=2&seg=1&dl=https%3A%2F%2Fwww.themix.org.uk%2Fmental-health%2Fsuicide&dr=https%3A%2F%2Fwww.google.com%2F&dt=Suicide%20%26%20Suicidal%20Thoughts%20%7C%20Mental%20Health%20%7C%20The%20Mix&en=user_engagement&_et=2221
Google Translate and Google reCaptcha
These both load on the site, but less obviously receive browsing behaviour. Both have capabilities to (as part of translating a page or receiving recaptcha action information), but this has not been checked.
Both load with Google user cookies and both are providing Google with a measure of how much you are using The Mix website.
It was worse
If you can believe it, the above is from checking on the 19th October 2023.
However, the complaint with The Mix was raised 31st January 2023
At that point it also included Facebook tracking and YouTube tracking without consent.
Consent for at least YouTube is possibly in a worse place, as video support material should not be withheld unless a child consents to advertisers tracking them.
Would this happen in a face to face service?
Would an adult ask a child: can I share your identifiable interest in suicide support material with several advertising companies to improve our marketing performance?
Would a community, school or health support service invite advertising company data collectors to sit in their reception and start noting which children are picking up which leaflets?
It would be sickening to see this happen physically, it should be no less sickening to see this is happening digitally.
Raising the complaint
31st January 2023: Complaint raised with The Mix and the ICO explaining various tracking integrations.
8th March 2023: The Mix reply advising their service is anonymous
Many thanks for your submission to The Mix. There is a huge amount of very valuable feedback here. I have passed your email to our technical and marketing team to review in depth, including the link to your website at https://kidsharms.com
The Mix is an anonymous service for young people and we do not routinely collect personal details or health data in our services except in safeguarding interventions via our 121 helpline services or when young people are working directly with our counsellors; this is only done with young people’s consent, held securely for a time limited period and not passed to outside agencies.
I am informed by the team that we display social widgets only on our main page and listing pages (i.e. category pages) because of that, even with the social network tracking enabled, information about the specific articles that our users have read is not likely to be available to anyone apart from us and Google Analytics. Additionally, no personal data is shared with Google, only basic or aggregated demographics.
In line with data protection guidance, we have a CookieBot widget that allows our users to manage cookies set in the browser. Specific cookie categories can be rejected by the user to further block any tracking should they wish.
I do not feel your description of The Mix sharing young people mental health problems with advertising systems is a fair or accurate representation of our work.
You make a good point about YouTube and whether we have effectively classed our YouTube api to exclude children. The age restriction is similar across most common social media platforms of 13. I have asked the team to look at this more in depth; in particular, whether more signposting or technical development is needed.
If my team require additional clarification on any of the points you have raised, we will be in touch.
Please be assured that The Mix is an anonymous service for young people and we take their privacy very seriously. I am grateful to receive your insight on how we might better improve our services, however I do not feel a report to the ICO is warranted or necessary at this stage.
I do apologise for the time it has taken to respond to your email. We are a small team and often extremely busy in our work. Once again, thank you for taking the time to conduct this valuable review of work.
9th March 2023: I replied repeating much of the complaint and providing additional details.
No reply from the ICO or The Mix since.