Privacy Groups: Kids Programming Should be Off YouTube

Privacy groups are warning the Federal Trade Commission about not taking the right steps to rein in YouTube if it finds reason to strike a consent decree with the site over its handling of children's personal info.

In a letter to the FTC, the Campaign for a Commercial-Free Childhood (CCFC) and the Center for Digital Democracy (CDD), which complained about children's content on the social media video site, said that any remedies of the alleged violation of the Children's Online Privacy Protection Act (COPPA) should not include leaving children's content on the site by " shift[ing] the burden of responsibility to content creators to opt out of 'interest-based' advertising."

It is a follow-up to a letter last month on the same issue.

"It is crucial that any proposed consent decree with YouTube or Google require the structural separation of the child-directed channels and videos, substantial civil penalties, and other relief requested in our letter of June 25, 2019," CFCC and CDD wrote in their follow up letter.

They told the FTC in the most recent letter that COPPA anticipates that more than one party can be liable for collecting personal information from a child in violation of COPPA, and YouTube and parent Google fit the bill. 

"As we explained in our request to investigate, Google and YouTube are operators in at least two different senses. First, YouTube operates a website,, a significant portion of which is directed at children....Second, Google operates the Google Marketing Platform (GMP), which...incorporates both the DoubleClick advertiser products and the Google Analytics 360 Suite. DoubleClick and other Google ad networks place trackers on child-directed channels on YouTube..."

Related: Sen Markey Says Kids Need Online Privacy Constitution

The FTC has not confirmed reports it is investigating YouTube, but CCFC and CDD filled a formal complaint against the site in April 2018, seeking potentially tens of billions of dollars in fines for what they said has been the company’s collection and sharing of children’s information.

FTC chair Joseph Simons told Sen. Ed Markey (D-Mass.), who backed the complaint and co-authored COPPA,  that if YouTube were indeed saying that a toy-review video was not directed toward kids, as Markey said was the case, the FTC would have a problem with that. But he would not comment on any possible investigation of the company over such issues. Markey then wrote the FTC with his own wish list of possible remedies. 

To which the privacy groups have added.

John Eggerton

Contributing editor John Eggerton has been an editor and/or writer on media regulation, legislation and policy for over four decades, including covering the FCC, FTC, Congress, the major media trade associations, and the federal courts. In addition to Multichannel News and Broadcasting + Cable, his work has appeared in Radio World, TV Technology, TV Fax, This Week in Consumer Electronics, Variety and the Encyclopedia Britannica.