Advocacy groups have requested that the Federal Trade Commission (FTC) conduct an investigation into YouTube’s handling of children’s data. The groups, including Fairplay, The Center for Digital Democracy, Common Sense, and Electronic Privacy Information Center (EPIC), sent a letter urging the regulatory agency to look into allegations that YouTube’s parent company, Google, is violating the Children’s Online Privacy Protection Act (COPPA) and its own rules.
This request comes in response to recent media reporting on ads placed on YouTube content for kids. It builds upon a separate report released by Adalytics, which raised concerns about Google’s handling of children’s data. Adalytics called on two senators to ask the FTC to investigate Google’s compliance with COPPA and its previous settlement with the FTC regarding potential COPPA violations.
Google strongly disputed the claims made in the Adalytics report, calling it “deeply flawed and misleading.” The company stated that ads appearing on children’s videos are based on webpage content, not targeted to user profiles.
In response to Google’s statement, Fairplay conducted a follow-up report to investigate ad targeting. Fairplay and ad buyers ran test ad campaigns on YouTube, selecting various user attributes and affinities for ad targeting. These ads were then instructed to run on “made for kids” channels. Despite YouTube’s policy stating that personalized ads are not shown on such content, the test campaign resulted in all 1,446 test ads running on the identified “made for kids” channels.
Moreover, the Audience Segment Report from Google indicated that each impression was targeted at one of the 21 audience segments selected for the campaign. Fairplay argues that if Google’s representations to advertisers are accurate, it would be in violation of COPPA.
Fairplay’s executive director, Josh Golin, has called for an immediate and comprehensive investigation by the FTC, stating that if Google and YouTube are found to be violating COPPA and their settlement agreement, the FTC should impose maximum fines for each violation.
This request for investigation is in line with a previous request made by Senators Ed Markey (D-Mass.) and Marsha Blackburn (R-Tenn.) following the release of the Adalytics report.
A spokesperson from Google responded to the allegations, stating that there is a “fundamental misunderstanding of how advertising works on made for kids content.” They emphasized that ads personalization is not allowed on such content, and Google does not offer advertisers the option to directly target made for kids content as a whole. Google has reached out to Fairplay to clarify their concerns and explain their protections.
In a prior response to the Adalytics report, Google criticized the focus on cookies as the basis for ad targeting and tracking on browsers. They highlighted that cookies are used for fraud detection and frequency capping, which are permitted under COPPA.
The pressure for an FTC investigation into YouTube is growing, alongside bipartisan support for updates to children’s online safety rules. Senator Markey’s proposal for COPPA 2.0, which would ban targeted advertising to children and introduce other measures, has advanced out of the Senate Commerce Committee with bipartisan support.
As the advocacy groups await action from the FTC, discussions continue regarding the need for stronger regulations to protect children online.
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