The Federal Trade Commission should insist that Google remove all children's content from YouTube in order to settle allegations that the company violated privacy laws, advocates say in a new letter to the agency.
The advocates specifically urge the FTC to reject any deal allowing companies to continue to post children's content to YouTube if they refrain from monetizing material with behaviorally targeted ads.
“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,” lawyers for watchdogs Center for Digital Democracy and Campaign for a Commercial-Free Childhood wrote in a letter sent to the agency on Wednesday.
Those groups alleged in an FTC complaint filed in April of 2018 that Google was violating the Children's Online Privacy Protection Act by knowingly collecting personal data from children younger than 13 without parental consent. The FTC has defined personal data to include geolocation information, unique device identifiers, mobile telephone numbers and other identifiers used to compile profiles and serve ads based on people's presumed interests.
The FTC is reportedly investigating Google over the allegations.
The new letter comes in response to a phone conference between FTC Chairman Joseph Simons, Commissioner Noah Phillips, and children's advocates.
During the call, an FTC Commissioner asked whether YouTube channels have the option to disable interest-based advertising, according to Josh Golin, executive director of the Campaign for a Commercial-Free Childhood.
“We became very concerned that that was a clue to part or all of the remedy the FTC is considering,” Golin says.
The watchdogs are now telling the FTC that disabling interest-based advertising won't resolve privacy concerns because companies may still be able to collect children's data, even if the information isn't used to target ads.
“It is unclear whether a child-directed channel on YouTube can prevent the collection of personal information from their viewers and subscribers,” the groups write. “It appears that by using advanced settings, a channel can opt to disable interest-based advertising...But it is not clear whether turning off interest-based advertising actually stops the data collection and tracking of the child via Google’s GMP [Google Marketing Platform] system.”
They also note that it's only possible to disable interest-based ads on channels, not individual videos. “Content creators who produce videos for a wide range of audiences would have to opt out and forgo the revenue of interest-based ads for all of their videos, even those produced for an adult audience, in order to avoid serving these ads to children,” the groups write.