Child consumer and privacy advocacy groups are claiming that YouTube Kids illegally collects information from their under-age audiences.
Advocacy groups filed a complaint on April 9, 2018, asking the Federal Trade Commission (FTC) to investigate YouTube Kids for violating the Child Online Privacy Protection Act (COPPA). The act limits the ways any company can collect information about children under the age of 13.
The law states that companies must notify parents and receive their consent before obtaining data on minors.
The complaint states, “Google has made substantial profits from the collection and use of personal data from children on YouTube. Its illegal collection has been going on for many years and involves tens of millions of US children.” There are 20 advocacy groups listed on the complaint, but they are led by the Center for Digital Democracy and Campaign for Commercial-Free Childhood.
According to YouTube’s terms of service, it is not for anyone under the age of 13. A Google account is required to sign into YouTube, and children under the age of 13 do not qualify for a Google account. They only way for children to watch YouTube Kids is to use their parent’s account or to lie to obtain a Google Account.
However, an account is not necessary to watch YouTube videos. According to Trendera Research, 45 percent of children between the ages of 8 and 12 have a YouTube account. They either use their parent’s accounts or lie about their ages to obtain a Google account of their own.
Channels that are focused on children have large subscriber bases and make significant amounts of money through advertisements.
LittleBabyBum shows animated nursery rhymes and has 14 million subscribers. Its videos have been viewed over 16 million times.
Ryan ToysReview, features a 6-year-old testing toys. The show made $11 million in ad revenue last year.
Google does not allow advertisers to target anyone under the age of 18, the complaint claims there are many ways to target children, such as choosing keywords that are related to children like “toy” and “toddler.”
YouTube Kids was launched in 2015. According to YouTube, the app follows all of the COPPA rules and does not collect information for ad targeting.
A Goggle spokesperson told CNN:
Protecting kids and families has always been a top priority for us. We will read the complaint thoroughly and evaluate if there are things we can do to improve. Because YouTube is not for children, we’ve invested significantly in the creation of the YouTube Kids app to offer an alternative specifically designed for children.
What is COPPA?
COPPA was written in 1998 and was expanded in 2012, to include more types of companies and new technologies, such as targeted ads and mobile devices. The FTC has pursued approximately 24 cases in 20 years.
If the FTC discovers that YouTube has violated COPPA, it could be forced to add and age gate, which is a screen that asks if the viewer is over 13.
According to the complaint, YouTube illegally collected information on 23 million children over a period of years. It wants the FTC to fine the app up to $41,484 per violation.
CEO of the COPPA consulting firm Privo, Denise Tayloe, believes the timing of the complaint could be due to the new European privacy regulations (GFPR). They go into effect in May.
Tayloe said, “The GDPR is really heating up the privacy space, putting a lot of pressure on Google, Facebook, and others to really acknowledge that they deal with children in the protected COPPA age range than they care to admit.”
Common Sense Media is a non-profit group and one of the 20 that signed the FTC complaint. The group reviews and rates media for parents. Common Sense Media Vice President Corbie Kiernan does not want to discourage content for children and worries that the age gate could just lead to lying and lack of protection because the child said they were over 13. They would rather keep the content and have Google and YouTube comply with the rules of COPPA.
How Google Gathers Data
According to Google’s privacy policies, they collect data to provide better services for their users. This includes the languages people speak, which advertisements would be most useful, the people who matter most to users, and which YouTube videos individuals would prefer.
Data is collected when people sign up for a Google Account. Personal information is gathered to store with the account. When people use Google services, more data is collected. What services are used? How are they used? What is being viewed on YouTube? Which advertisements are being interacted with? Do the websites visited use Google Advertising?
Here are examples of the data Google collects:
- Any information provided to Google to create an account.
- Email address(es)
- Telephone number
- Credit card number
- Photograph with Google Profile
- Device information – hardware model and operating system
- Unique device identifiers
- Search queries
- IP addresses
- Phone number
- Calling-party number
- Duration of calls
- SMS routing information
- Types of calls
- Device information: crashes, system activity, hardware setting, browser type, browser language, time and date of request, referral URL
- Location: use various technologies to determine locations, such as IP address, GPS, and other sensors that can provide Google with information on devices nearby including WIFI access points and cell towers
- Unique application numbers: some services have a unique application number. The number and information about the installation is sent to Google when a service is installed or uninstalled and the service contacts Google services for things like automatic updates
- Local storage: Google collects and stores information, including personal information on the user’s device(s) using browser web storage and application data caches.
- Cookies: Google and their partners use a variety of technologies to collect and store data when a user visits a Google service. This includes suing cookies to identify the browser and device. They collect and store data when the user interact with services offered by partners like advertising services or Google features that appear on other sites. Google Analytics helps businesses and site owners analyze traffic to their website and apps.
What Google Does With Collected Data
Information gathered when a user is signed into Google along with the information obtained about the user from partners could be associated with the Google Account. Data linked to a Google Account is treated as personal information.
The data collected from all of Google’s services and partners is used to maintain, provide, improve, protect, and develop new services. This information is also used to provide tailored content, such as more relevant search results and advertisements.
Information obtained from cookies and other technologies (pixel tags) are used to improve user experience and the overall quality of services. By saving the preferred languages used, Google will ensure their services use those languages when showing tailored advertisements. Google does not use identifiers in sensitive categories, such as religion, race, health, or sexual orientation.
Automated systems analyze user content, including emails, to provide personally relevant product features, ie customized search results, tailored ads, spam and malware detection.
Google may combine personal information from one service with data from other services.
The video-streaming website is the most popular online platform to children. In a recent study, it was determined that 80 percent of the children in the U.S., ages 6-12, use YouTube every day. Google collects and uses the data gathered from all users, regardless of age.
By Jeanette Smith
CNN: Groups claim YouTube illegally collects data from kids
Federal Trade Commission: Filling Document
Image Courtesy of SeRGioSVoX’s Flickr Page – Creative Commons License