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    Letter To Chair of The Federal Trade Commission

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    FOX 17 News Digital Staff
    1) Two US Senators wrote to the FTC Chair urging an investigation into reports that YouTube and Google may have violated COPPA and their own policies by tracking and targeting children without parental consent. 2) New research indicates YouTube ads are facilitating widespread collection and sharing of children's data without permission, as well as serving targeted ads on kids' videos in violation of YouTube's policies and 2019 FTC settlement. 3) The Senators ask the FTC to fully investigate any violations, ensure children's privacy is protected from companies' tracking and targeting, and take strong steps like stopping data collection from under-13s and deleting existing kids' data if violations are found.

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    Letter To Chair of The Federal Trade Commission

    Uploaded by

    FOX 17 News Digital Staff
    1K views3 pages
    1) Two US Senators wrote to the FTC Chair urging an investigation into reports that YouTube and Google may have violated COPPA and their own policies by tracking and targeting children without parental consent. 2) New research indicates YouTube ads are facilitating widespread collection and sharing of children's data without permission, as well as serving targeted ads on kids' videos in violation of YouTube's policies and 2019 FTC settlement. 3) The Senators ask the FTC to fully investigate any violations, ensure children's privacy is protected from companies' tracking and targeting, and take strong steps like stopping data collection from under-13s and deleting existing kids' data if violations are found.

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    Letter to Chair of the Federal Trade Commission

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    Letter to Chair of the Federal Trade Commission

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    1) Two US Senators wrote to the FTC Chair urging an investigation into reports that YouTube and Google may have violated COPPA and their own policies by tracking and targeting children without parental consent. 2) New research indicates YouTube ads are facilitating widespread collection and sharing of children's data without permission, as well as serving targeted ads on kids' videos in violation of YouTube's policies and 2019 FTC settlement. 3) The Senators ask the FTC to fully investigate any violations, ensure children's privacy is protected from companies' tracking and targeting, and take strong steps like stopping data collection from under-13s and deleting existing kids' data if violations are found.

    Copyright:

    © All Rights Reserved
    Download as PDF, TXT or read online from Scribd
    Download as pdf or txt
    1K views3 pages

    Letter To Chair of The Federal Trade Commission

    Uploaded by

    FOX 17 News Digital Staff
    1) Two US Senators wrote to the FTC Chair urging an investigation into reports that YouTube and Google may have violated COPPA and their own policies by tracking and targeting children without parental consent. 2) New research indicates YouTube ads are facilitating widespread collection and sharing of children's data without permission, as well as serving targeted ads on kids' videos in violation of YouTube's policies and 2019 FTC settlement. 3) The Senators ask the FTC to fully investigate any violations, ensure children's privacy is protected from companies' tracking and targeting, and take strong steps like stopping data collection from under-13s and deleting existing kids' data if violations are found.

    Copyright:

    © All Rights Reserved
    Download as PDF, TXT or read online from Scribd
    Download as pdf or txt
    of 3

    August 17, 2023

    The Honorable Lina Khan


    Chair
    Federal Trade Commission
    600 Pennsylvania Avenue, NW
    Washington, DC 20580

    Dear Chair Khan:

    We write following recent reporting that reveals YouTube and Google may have violated the
    Children’s Online Privacy Protection Act (COPPA) and their own policies by tracking and
    targeting kids without parental notice and consent.1 New research from Adalytics indicates
    YouTube and Google are facilitating the vast collection and distribution of children’s data
    without parental consent, as well as disregarding YouTube’s own policies and its 2019 FTC
    consent decree by showing targeted advertisements on videos for kids.2 We therefore urge the
    Federal Trade Commission (FTC) to use its full authority under the COPPA and the FTC Act to
    investigate and remedy any violations and ensure children are protected from tracking and
    targeting by YouTube and Google.

    In 2019, the FTC fined YouTube and Google $170 million for YouTube’s violations of COPPA.3
    Shortly thereafter, YouTube released new policies stating that any user watching child-directed
    content would be treated like a child, which included limiting data collection on viewers of child-
    directed content.4 Additionally, YouTube stated it would stop serving personalized – or targeted
    – advertisements on any children-directed videos.5 These changes would have been important
    protections for children who regularly use YouTube. Targeted advertising can manipulate
    children,6 and companies routinely use personal information to pressure young people to spend

    1
    Nico Grant, Natasha Singer, and Aaon Krolik, YouTube Ads May Have Led to Online Tracking of Children,
    Research Says, New York Times (Aug. 17, 2023), https://www.nytimes.com/2023/08/17/technology/youtube-
    google-children-privacy.html.
    2
    Are YouTube Advertisers Inadvertently Harvesting Data From Millions of Children?, Adalytics. (Aug., 2023),
    https://adalytics.io/blog/are-youtube-ads-coppa-compliant.
    3
    Press Release, Federal Trade Commission, Google and YouTube Will Pay Record $170 Million for Alleged
    Violations of Children’s Privacy Law (Sept. 4, 2019).
    4
    Susan Wojciki, An update on kids and data protection on YouTube, YouTube Official Blog (Sept. 4, 2019),
    https://blog.youtube/news-and-events/an-update-on-kids/.
    5
    Id.
    6
    Matthew Lapierre et al., The Effect of Advertising on Children and Adolescents, Pediatrics (2017), 140 (2) S152-
    S156; doi:10.1542/peds.2016-1758V; Laura Owen et al., Is Children’s Understanding of Non–Traditional
    Advertising Comparable to their Understanding of Television Advertising?, Journal of Public Policy Mark (2021),
    32(2):195–206 doi.org/10.1509/jppm.09.003.
    The Honorable Lina Khan
    Page 2
    August 17, 2023

    more time on their platforms, which can have many negative impacts.7 However, these policies
    are only helpful if companies abide by them. Unfortunately, this new research indicates that
    YouTube and Google may once again be violating COPPA and breaking their own policies by
    serving targeted advertisements on kids-directed content.

    First, the research from Adalytics indicates YouTube and Google are facilitating the collection
    and distribution of children’s data without parental consent.8 Per COPPA requirements,
    YouTube is responsible for obtaining parental consent prior to sharing personal information with
    advertisers or delivering a targeted advertisement.9 According to this study, however, child-
    directed videos are flooded with advertisements that, when clicked, collect data that is
    immediately shared with an unknown number of data brokers and companies, all without
    parental consent.10 For instance, Google allegedly markets its own products on YouTube’s child-
    directed videos and collects information without parental consent when an advertisement is
    clicked.11 The researchers found that YouTube channels that are popular with kids produced the
    most clicks for some of the personalized advertisement campaigns on the platform.12

    Second, the research suggests the companies may have violated YouTube policies by showing
    targeted advertisements on videos for kids.13 For example, it finds that YouTube and Google
    may still being using audience identifiers to target advertisements on kids-directed content—
    something that, if true, would directly violate YouTube’s policies.14

    This behavior by YouTube and Google is estimated to have impacted hundreds of thousands, to
    potentially millions, of children across the United States.15 As such, YouTube and Google may
    have violated COPPA – as well as its 2019 FTC consent decree – in an egregious manner.

    Therefore, we urge the Commission to act swiftly and use its authority under COPPA and the
    FTC Act to investigate and hold YouTube and Google accountable for violations of these laws
    and YouTube’s 2019 consent decree. If violations are in fact found, we encourage the FTC to
    take strong and swift steps to stop YouTube and Google from collecting data from any user
    known to be under 13, delete all data under their control collected from children under 13 (even

    7
    Georgia Wells, Jeff Horwitz, and Deepa Seetharamn, Facebooks Knows Instagram Is Toxic for Teen Girls,
    Company Documents Show, Wall Street Journal (Sept. 14, 2021), https://www.wsj.com/articles/facebook-knows-
    instagram-is-toxic-for-teen-girls-company-documents-show-11631620739.
    8
    Are YouTube Advertisers Inadvertently Harvesting Data From Millions of Children?, Adalytics. (Aug., 2023),
    https://adalytics.io/blog/are-youtube-ads-coppa-compliant.
    9
    Federal Trade Commission, Complying with COPPA: Frequently Asked Questions, https://www.ftc.gov/business-
    guidance/resources/complying-coppa-frequently-asked-questions#L.%20Disclosure%20of%20Information.
    10
    Are YouTube Advertisers Inadvertently Harvesting Data From Millions of Children?, Adalytics. (Aug., 2023),
    https://adalytics.io/blog/are-youtube-ads-coppa-compliant.
    11
    Id.
    12
    Id.
    13
    Id.
    14
    Id.
    15
    Id.
    The Honorable Lina Khan
    Page 3
    August 17, 2023

    if the user is now 13 or older), and prevent YouTube and Google from monetizing the data of
    these children.

    We also urge the FTC to use its full authority to address any downstream impacts of YouTube
    and Google’s collection and distribution of children’s data, including investigating how this data
    has been used by advertisers and data brokers.

    YouTube and Google cannot continue treating young people’s data as an unprotected commodity
    from which to profit with abandon. Not only must the FTC act, but Congress must also pass
    legislation to protect young people’s privacy online and finally ban targeted advertising to kids
    and teens. We look forward to working with the Commission to ensure young people continue to
    have strong privacy protections.

    Thank you for your attention to this important matter.

    Sincerely,

    Edward J. Markey Marsha Blackburn


    United States Senator United States Senator

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