At Kids Industries we have Super Six guiding principles to ensure happy and healthy childhoods in the 21st century, which is threaded into everything we do as a family-focused marketing agency.
Number one of the Super Six is safeguarding, so imagine my concern when I hear that there’s a potential repeat offender in the realm of children’s data privacy in the form of Google-owned video platform, YouTube. After having a good dig around to get further clarity, it appears that both sides of the argument are a bit opaque… despite their protestations.
The fact that we are even having this conversation is beyond ridiculous. But this is not going to go away and maybe that’s a good thing. We need to work through all the extremities to get to the truth and a globally workable regulatory framework that enables that precarious dance of commerce and privacy to keep step a little more.
Whatever the reality, the bottom line is that protecting our children’s privacy is a fundamental of a safe internet and it should not be complicated. At its core this is about Google and YouTube appearing to serve demographically and behaviourally targeted ads on Made For Kids (MFK) channels.
And it certainly looks like this is happening. But it shouldn’t be.
A coalition of the caring in the form of Fairplay, The Center For Digital Democracy, Common Sense and The Electronic Privacy Information Center, sent a letter this week asking the FTC to investigate Google,YouTube and this whole sorry kahuna as a violation of COPPA.
These organisations don’t do this for shits and giggles, it’s what they exist to do. Due diligence will have been carried out and, given the $170M fine issued back in 2019, this accusation of repeat offending is about as serious as it gets. Telling a straight story is vital.
Fairplay even ran its own tests – 1,446 ads specifically adapted to NOT target kids – and yet each and every one showed up in channels targeting children.
Google is explicit on this – any viewer of the content on MFK channels should be considered a child – and that means there will be zero placement of ads targeting adults. So it’s all a bit weird really.
Google says that the report from research firm Analytics (which kicked this all off) doesn’t understand how its cookies work and that actually, they are well within the parameters of COPPA which allows the use of cookies for fraud protection and frequency capping.
But what is happening is that the YouTube ads are being served that aren’t for kids and they are taking children to third party sites where they no longer have the supposed protection. And those third parties are then in breach as they open their whole cookie jar onto the user to maximise their opportunities to make the sale or worse, influence the mind.
Either children’s data is being used within the law or it is not. With this stuff there should be no grey areas. And that’s the thing that bothers me most.
The spirit of preserving the privacy of the children becomes corrupted by the lawyers’ application of an underdeveloped regulatory framework – both on YouTube and elsewhere – and we enter these ridiculous cycles of point and counterpoint. At this point, the humanity of it all – the future of the next generation – becomes mired in debate, where in reality there should be no debate.
It’s clear we aren’t there yet and it’s going to take time, but I hope that events like these continue to refine and wash out the foibles of the legislative framework.
Although this is happening 3,000 miles away, it is impacting us all and we’re talking about it and those with a duty of care are exerting that care. And that bodes well for a future where YouTube – and the rest of the internet – is actually safe for children.
Currently we have two sides of the argument and each is emphatic in its position. I have a feeling that there’s something else going on here. Perhaps YouTube is because the planet’s biggest video platform, largest ad placement business and most popular browser are one ecosystem is conflating and literally getting their wires crossed.
Maybe there is a little tag called ‘kids’ somewhere in the matrix that is Google and maybe it’s playing with all our realities. Regardless, it just needs to stop.
