Child protection in marketing communications as corporate social responsibility in Vietnam: A Stakeholder Theory approach

ABSTRACT:

Grounded in the stakeholder theory and relevant legal frameworks, this study examines Vietnam’s regulatory approach to protecting children in marketing communication activities. The analysis shows that Vietnam has developed a relatively comprehensive policy framework, encompassing the 2012 Law on Advertising, the 2016 Law on Children, the 2023 Law on Consumer Protection, Decree No. 13/2023 on personal data protection, and inter-agency coordination programs for child protection in the online environment. Drawing on stakeholder theory and the principle of power-proportionate responsibility, the study analyzes the roles and responsibilities of key actors involved in marketing activities targeting or affecting children. The findings highlight the limitations of a governance approach that relies primarily on general regulations and post-violation enforcement, underscoring the significance of multi-stakeholder involvement in enhancing the effectiveness of child protection in contemporary marketing practices.

Keywords: child protection policy, marketing, communication, CSR, stakeholder theory.

1. Introduction

According to Datareportal (2025) as of February 2025, Vietnam recorded 79.8 million Internet users, accounting for 78.8% of the total population (approximately 101 million people). Compared to 2024, the number of Internet users increased by 0.3%, corresponding to approximately 223,000 people. Regarding usage frequency, on average, each person spends more than 6 hours/day accessing the Internet on multiple devices, with smartphones being the most popular device (95.4%, up 0.9%), followed by laptops/personal computers (60.1%, up 7%), tablets (30.2%, up 3.9%), and Internet-connected TVs (27.1%, up 5.2%). According to Thien Lam (2025), there is a clear differentiation in the amount of time children spend on the Internet each day: 27.1% of children use the Internet for less than 1 hour per day, while the largest group, 47.9%, spends 1–3 hours per day. In addition, 18.8% of children use the Internet for 4–6 hours per day, and notably, 2.3% of children use it for more than 10 hours per day, indicating that there is still a group of children with very high levels of Internet exposure.

Meanwhile, policies on advertising and child protection in Vietnam are often viewed from a "law-and-punishment" perspective, but in reality, advertising is seen as a multi-stakeholder ecosystem. Therefore, the study focuses on analyzing current advertising policies in Vietnam based on stakeholder theory and how responsibilities are allocated among stakeholders regarding child protection, as well as the degree to which a balance between business interests and social ethics has been achieved.

2. Theoretical basis and analytical framework

2.1. Stakeholder theory

Businesses are social institutions, and therefore have the ability to impact society in many different ways (Buchholz, 1993). These impacts can be positive, such as creating jobs and promoting economic growth, but they can also be negative, such as causing environmental pollution and contributing to climate change.

In the context of Marketing communication, stakeholder theory, proposed and developed by R. Edward Freeman, provides an important basis for assessing the social impact of business activities, especially on vulnerable groups such as children. Rather than viewing advertising solely as an interaction between businesses and consumers, this theory expands the scope of analysis to the entire ecosystem, including businesses, media outlets, digital platforms, families, schools, and regulatory agencies.

2.2. Multi-level analysis framework (Hard law - Soft law - Platform governance)

The multi-level analysis framework (Hard law - Soft law - Platform governance) is an approach used to analyze and evaluate policies in areas where business conduct is not only governed by state law but also regulated by informal standards and digital platform regulations.

In the context of today's rapidly developing digital environment, child protection policies cannot rely solely on the state legal system (hard law), but must be viewed within a multi-level governance framework comprising hard law - soft law - platform governance. Accordingly, laws (hard law) play a role in establishing minimum standards and sanction mechanisms; industry self-regulation mechanisms (soft law) provide support through informal ethical standards; and digital platform rules (platform governance) directly determine whether advertising content is distributed, removed, or restricted from children through the platform policies of each different digital platform.

3. Research methodology

This study uses qualitative research analysis methods, combining multiple data sources. The study focuses on analyzing the content of legal documents and policies directly related to marketing communication, and child protection activities, including the Advertising Law, the Consumer Protection Law of 2023, Decree 13/2023/NĐ-CP on personal data protection, and the Program for the Protection and Support of Children's Healthy and Creative Interaction in the Online Environment for the 2021-2025 period.

On that basis, the study analyzes stakeholders according to Stakeholder Theory, focusing on identifying the roles, interests, risks, responsibilities, and coordination mechanisms among entities in the advertising and marketing ecosystem related to children, thereby assessing the level of responsibility and the ability to balance business interests and social ethical requirements.

4. Current status of child protection policies in marketing communication activities in Vietnam

4.1. Research context

According to Datareportal (2025), in January 2025, Vietnam recorded 79.8 million Internet users, corresponding to 78.8% of the total population, indicating that the penetration of the digital space has reached a widespread scale. Along with that, social media continues to play an important role in digital life in Vietnam with 76.2 million active social media user accounts, equivalent to 75.2% of the population, an increase of 3.5 million accounts (4.8%) compared to the beginning of 2024. Notably, 95.4% of Internet users used at least one social media platform in January 2025. Demographically, the social media user structure is relatively balanced, with 51.2% female and 48.8% male.

At the platform level, YouTube reached 62.3 million users (advertising audience), equivalent to 61.5% of the population and 78.0% of Internet users, despite a decrease in advertising reach of 700,000 (1.1%) compared to the beginning of 2024; meanwhile, Facebook reached 76.2 million users (advertising audience), equivalent to 75.2% of the population, with an increase of 3.5 million (4.8%), and had a very high penetration rate among those aged 13 and above (93.5%) as well as adults aged 18 and above (103.5%). In addition, Instagram recorded 10.6 million users (10.4% of the population) and a decrease of 350,000 (3.2%) in advertising reach; TikTok had 40.9 million users aged 18 and above (advertising audience) but saw a sharp decline in advertising reach of 26.9 million (39.7%); Messenger reached 55.9 million users (55.2% of the population) and increased by 1.40 million (2.6%); LinkedIn has 8.90 million members (8.8% of the population) and increased by 1.4 million (18.7%); while the X (Twitter) platform recorded 6.29 million users (6.2% of the population), an increase of 706 thousand (12.6%). The high rate of internet and social media users creates conditions for digital advertising to strongly penetrate daily life, including among children.

4.2. Policies to protect children in marketing communication activities in Vietnam

In Vietnam, the 2012 Law on Advertising, amended and supplemented in 2025, stipulates in Article 8, Clause 14: “Advertising that causes children to have thoughts, words, or actions contrary to morality and good customs; or adversely affects the health, safety, or normal development of children” is prohibited. This provision has significant legal value and is consistent with the spirit of prioritizing vulnerable groups in stakeholder theory.

The 2023 Law on Consumer Protection (Law No. 19/2023/QH15, effective from July 1, 2024) officially recognizes children as one of the vulnerable consumer groups alongside the elderly, people with disabilities, ethnic minorities, pregnant women/women with young children, people with serious illnesses, and members of poor households, thereby increasing the priority of protecting the rights of these groups and requiring businesses and individuals to have greater responsibility and special dispute resolution mechanisms.

Additionally, the government has issued Decree 13/2023/NĐ-CP on personal data protection. Article 20 of this decree clearly stipulates the processing of children's data. The regulation has created an important basis for restricting targeted advertising based on children's data, but in reality, the biggest “bottleneck” lies in age verification and checks by digital platforms.

The 2016 Law on Children serves as an important legal foundation in Vietnam's child protection policy system, establishing the principles and responsibilities of the State, families, schools, and society in ensuring children's rights, including the right to be protected from risks of abuse, violence, and exploitation in various forms, including online child protection programs. The program “Protecting and supporting children to interact healthily and creatively in the online environment for the period 2021-2025” was approved by the Prime Minister under Decision No. 830/QĐ-TTg, clearly expressing the direction of interdisciplinary and proactive governance, shifting the focus from a “prevention” approach to a “protection and support” model for children in cyberspace. In addition, the Ministry of Information and Communications has also issued many documents to strengthen prevention and response capabilities, such as Decision No. 2264/QĐ-BTTTT dated December 22, 2020 on approving the Program to prevent and combat child abuse in the online environment, as well as Decision No. 716/QĐ-BTTTT dated May 26, 2021 on the establishment of a network to rescue and protect children in the online environment.

On that basis, media agencies have actively promoted activities to raise awareness about the prevention and control of child abuse in general and the protection of children in the online environment in particular. At the same time, functional agencies have strengthened coordination in organizing the implementation of policies and laws, promoting inspection, examination, verification, and timely handling of violations, especially harmful content on the Internet. These efforts have contributed to strengthening conditions for children to use the online environment safely and healthily, while improving their ability to access and utilize positive and useful information sources for learning and development (Nguyen Huu Thanh, 2023).

On March 23, 2023, Deputy Minister of Information and Communications Nguyen Thanh Lam signed and issued Official Letter No. 956/BTTTT-PTTH&TTĐT, which requires advertising service businesses in Vietnam, brands, and Vietnamese businesses engaged in advertising activities to strictly comply with legal regulations on advertising. The Ministry also stipulated serious violations of current legal regulations, including content related to Decree No. 70/2021/ND-CP (amending and supplementing a number of articles of Decree No. 181/2013/ND-CP) guiding the implementation of the Law on Advertising. In 2024, the Ministry announced 904 websites with signs of violating the law, related to illegal betting, illegal games, etc. This reflects two issues: (i) the large amount of  “risky content supply”, (ii) if the advertising value chain lacks scrutiny, advertising money can still flow into “hot spots”, which indirectly increases the risk of children being exposed to harmful content.

5. Analyzing child protection policies in marketing communication activities in Vietnam based on the stakeholder theory

From Table 1, it can be concluded that the policy on protecting children in Marketing communication activities in Vietnam has formed a relatively comprehensive system of regulations and policies, affecting most key stakeholders in the advertising and Marketing ecosystem related to children. Specifically, the 2012 Law on Advertising strictly prohibits advertising practices that could negatively impact children; The 2016 Law on Children establishes the legal basis for children’s rights and the protection responsibility of the State, families, and society; simultaneously, the 2023 Law on Consumer Protection further expands the scopes of protection by recognizing children as a vulnerable consumer group, thereby increasing their priority in the protection mechanism.

In addition, Decree 13/2013/ND-CP adds an important layer of legal related to children’s personal data, which is particularly significant in the context of increasingly prevalent digital advertising and data targeting. Finally, the Program for the Protection and Support of Children’s Healthy and Creative Interaction in the Online Environment for the 20121-2015 period contributes to strengthening inter-sectoral coordination mechanisms and risk prevention in the online space.

Table 1. Key legal responsibilities in Marketing communication activities involving children for stakeholders in Vietnam

Source: Author's compilation

However, in terms of balancing responsibilities, the policy system still has an imbalance of obligations between parties and does not impose commensurate restrictions on powerful entities such as digital platforms and advertising technology (adtech) systems, while parents and schools often have to play a major supervisory role but lack supporting tools. Regarding enforceability, regulations have made efforts to control online advertising and promote inter-agency coordination, but challenges remain in monitoring digital advertising, false advertising, and the activities of cross-border platforms such as Facebook, Tiktok, etc., highlighting the need to continue refining specific enforcement standard to better protect children in the digital environment.

6. Conclusions and policy implications

Based on the stakeholder theory and reference to the relevant legal framework, it can be concluded that Vietnam has established a relatively comprehensive policy framework to protect children in advertising and Marketing activities, including the 2012 Advertising Law, the 2016 Children's Law, the 2023 Consumer Protection Law, Decree 13/2023 on personal data protection, and inter-agency coordination programs on child protection in the online environment. However, in the context of the rapid growth of the digital environment, the current policy system still has limitations because many new regulations remain at the level of principles and have not been translated into specific implementation standards for modern forms of advertising such as data-driven advertising and cross-border digital platform advertising. There is an imbalance between roles and responsibilities in the advertising ecosystem, where powerful entities (digital platforms, advertising technology systems, and brands) are not bound by obligations commensurate with their level of influence, while the responsibility to protect children tends to be “pushed” onto parents and schools—entities that have a high level of concern but limited tools and capacity to control children.

Based on the stakeholder theory and the principle of “responsibility commensurate with power”, Vietnam needs to shift from an approach primarily based on general regulations and post-violation handling to a multi-stakeholder governance model in the field of advertising related to children. The policy focus should first aim to improve specific regulations for digital advertising by issuing guidelines or specific standards for advertising that targets or is likely to reach children, especially new forms such as influencer Marketing, livestream sales, and embedded advertising. At the same time, the policy needs to increase the responsibility of digital platforms and advertising technology (adtech) systems in controlling ad distribution. In addition, it is necessary to establish a “chain of responsibility” mechanism in advertising activities, promoting joint responsibility between brands, advertising companies, content creators, and platforms, where brands are not only responsible for advertising messages but also for assessing the display environment (brand safety) and controlling implementation partners, in order to reduce fragmentation of responsibility and the phenomenon of “passing the buck” when risks to children arise.

Alongside legal measures, it is necessary to strengthen support tools and improve the capacity of parents and schools in monitoring, guiding children to use the internet safely, and identifying advertising content; however, these measures should only play a supplementary role and not replace the primary responsibility of powerful entities in the advertising ecosystem. Finally, to enhance the effectiveness of child protection in the context of rapidly developing digital advertising, Vietnam needs to continue to promote inter-agency coordination and strengthen enforcement mechanisms in a cross-border environment, including cooperation between regulatory agencies, service providers, and advertising companies to deal with violations in a timely manner, while strengthening the capacity to monitor online advertising and manage children's personal data in the digital environment.

References:

1. Buchholz, M. B. (1993). Die Rolle der Prozeßphantasie in der stationären Psychotherapie. Journal für Psychologie, 1(4), 64–81.
2. Government. (2023). Decree No. 13/2023/NĐ-CP dated April 17, 2023 on personal data protection.
3. DataReportal. (2025). Digital 2025: Vietnam.
4. Freeman, R. E. (1984). Strategic Management: A Stakeholder Approach.
5. Nguyen Huu Thach. (2023). Strengthening the protection of children under the influence of the internet today. Social Sciences Human Resources, (12), 92–100.
6. National Assembly. (2012). Advertising Law No. 16/2012/QH13.
7. National Assembly. (2023). Law on Consumer Protection No. 19/2023/QH15.
8. Thien Lam. (2025). Measuring the risks to children's safety and development in cyberspace. People's Newspaper.
9. Prime Minister. (2021). Decision No. 830/QĐ-TTg dated June 1, 2021 approving the Program “Protecting and supporting children to interact healthily and creatively in the online environment for the period 2021–2025”.
10. Vietnam News. (2023, March 20). Children face risks in cyberspace with 87 per cent accessing internet daily.

Chính sách bảo vệ trẻ em trong hoạt động truyền thông marketing như một hoạt động trách nhiệm xã hội của doanh nghiệp tại Việt Nam: Tiếp cận theo lý thuyết các bên liên quan

Lê Thị Việt Hà¹

Hồ Linh Trang²

Đỗ Thị Mỹ Trang³

Lê Quang Minh⁴

Lê Cẩm Tú⁴

Phạm Trần Huyền Linh⁴

Nguyễn Diệu Linh⁴

¹Viện Quản trị kinh doanh, Trường Đại học Kinh tế, Đại học Quốc gia Hà Nội

²Khoa Tài chính Ngân hàng, Trường Đại học Kinh tế, Đại học Quốc gia Hà Nội

³Khoa Kinh tế phát triển, Trường Đại học Kinh tế, Đại học Quốc gia Hà Nội

⁴Khoa Kinh tế và Kinh doanh quốc tế, Trường Đại học Kinh tế, Đại học Quốc gia Hà Nội

TÓM TẮT:

Dựa trên lý thuyết các bên liên quan và các khung pháp lý có liên quan, nghiên cứu này phân tích cách tiếp cận quản lý của Việt Nam đối với việc bảo vệ trẻ em trong các hoạt động truyền thông marketing. Kết quả phân tích cho thấy Việt Nam đã xây dựng một khung chính sách tương đối toàn diện, bao gồm Luật Quảng cáo năm 2012, Luật Trẻ em năm 2016, Luật Bảo vệ quyền lợi người tiêu dùng năm 2023, Nghị định số 13/2023 về bảo vệ dữ liệu cá nhân, cùng các chương trình phối hợp liên ngành về bảo vệ trẻ em trong môi trường trực tuyến. Trên cơ sở vận dụng lý thuyết các bên liên quan và nguyên tắc “trách nhiệm tương xứng với quyền lực”, nghiên cứu làm rõ vai trò và trách nhiệm của các chủ thể then chốt tham gia vào các hoạt động marketing có tác động đến trẻ em. Các phát hiện cho thấy những hạn chế của mô hình quản lý chủ yếu dựa vào quy định chung và xử lý sau vi phạm, đồng thời nhấn mạnh tầm quan trọng của sự tham gia đa bên trong việc nâng cao hiệu quả bảo vệ trẻ em trong bối cảnh các thực tiễn marketing đương đại.

Từ khóa: chính sách bảo vệ trẻ em, marketing, truyền thông, trách nhiệm xã hội của doanh nghiệp, lý thuyết các bên liên quan.

[Tạp chí Công Thương - Các kết quả nghiên cứu khoa học và ứng dụng công nghệ, Số 3 năm 2026]