YouTube COPPA Compliance: Just The Facts

Earlier this year, a settlement between Google and the Federal Trade Commission (FTC) included a requirement that YouTube develop and implement a system that helps advertisers and channel owners comply with the Children’s Online Privacy Protection Act (COPPA).

What Is COPPA?

The Children’s Online Privacy Protection Act (COPPA), effective beginning in 2000, is a federal law that deals with how the data of children under the age of 13 is collected by websites, apps and other online platforms.

Why Is COPPA In The News?

On November 12, YouTube officially began the implementation of the system required by the FTC settlement. Although YouTube, like all online platforms, has always been obligated to comply with COPPA, Google confirms that their new, more stringent measures are a result of the settlement. The measures include:

• Indicating the intended audience for all content on YouTube
• Eliminating comments, notifications and personalized ads from children’s content
• Extremely limited collection of children’s personal data

What Changes Is YouTube Making To Kids’ Content To Comply With COPPA?

Beginning in January, YouTube will start the process of disabling certain features, including “comments, notifications and others.” The process of eliminating these features will happen gradually as YouTube fixes bugs and refines the new look of YouTube content for kids. In the meanwhile, creators should expect to see small changes prior to the final rollout of the broad platform change.

YouTube is also increasing their promotion of YouTube Kids and reducing the number of questionable channels on the app to make it a more family-friendly, safe option for kids who use YouTube.

How Can Content Creators Be COPPA Compliant On YouTube?

All content creators on YouTube, regardless of their location or intended audience, must indicate if their content is created for children. This first step of compliance, according to Google, requires creators to choose an  “audience setting.” YouTube makes this easy for creators with a setting in YouTube Studio, allowing creators to set audiences at either the channel or video level — the video setting needs to be done for each video, while the channel setting is for all existing and future content.

As explained in the Google blog, machine learning is also being used to determine which videos are directed at children: “We’ll also use machine learning to help us identify videos that are clearly directed to young audiences. We trust you to set your audience accurately, but we may override your audience setting choice in cases of error or abuse.” Creators struggling to ascertain the proper setting can consult the Google help center, or legal counsel, and should not rely strictly on YouTube’s machine learning, which could misfire, or YouTube analytics, which are not designed to detect if content is directed at children.

How Will Advertisers Be Impacted By The COPPA Changes?

At the heart of the FTC settlement with Google were allegations that YouTube wasn’t careful with the personal data of children using the video platform, violating COPPA regulations. In response, YouTube will now entirely prohibit personalized advertisements on content with an audience setting for children and limit data collection to what is necessary “to support the operation of the service,” according to a Google blog addressing the pending changes. It will appear that personalized ads are turned off for kid content. However, like comments and notifications, personalized ads will actually not stop serving until testing is complete and the new compliance system is ready to roll out across the platform.

In a breakdown of how COPPA compliance could impact advertisers, IAB said, “While COPPA does not prohibit advertising to children, it states that you may not collect any personal information (which includes cookies and other persistent identifiers) from children under 13 years of age without verifiable parental consent. This is intended to stop, among other things, the behavioral advertising, retargeting and profiling of children under 13.” Advertisers are still free to advertise to children, but IAB suggests contextual advertising for delivery and execution of ads that meet COPPA compliance.

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