FTC Urged to Investigate Google for Advertising to Children

Fairplay and Common Sense Media, children’s advocacy organizations, have urged the Federal Trade Commission to launch an investigation into Google. They claim that Google is in violation of federal law by delivering personalized advertisements to children on YouTube.

The letter follows a report published last week by The New York Times that YouTube ads may have led to online tracking of children. The federal Children’s Online Privacy Protection Act, or COPPA, requires websites aimed at children to obtain parental consent before collecting personal information from children under the age of 13.

In response to the Times report, Google said last week that it did not serve targeted ads on children’s videos and that its advertising practices fully comply with COPPA. When the ads appear in children’s videos, the company told the Times, they are based on the content of the web pages, not targeted to user profiles.

But Wednesday’s letter to the FTC — also signed by the nonprofit Center for Digital Democracy — says Fairplay and independent ad buyers conducted follow-up research that suggests the ads are, in fact, personal. They did this by running test ad campaigns on YouTube, selecting a set of users with attributes and relationships to target ads to, and telling Google to only show ads on channels made for kids.

The groups say that, in theory, these test campaigns should have resulted in zero placements because Google and YouTube’s policy is not to show tailored ads on videos made for children. But Fairplay says its targeted $10 ad campaign generated more than 1,400 impressions on “made for children” channels, with ad buyers reporting similar results.

Google said the report’s findings point to a fundamental misunderstanding of how advertising works in content made for children.

“We do not allow personalization of ads for content made for children, and we do not allow advertisers to target ads to children in any of our products,” the company said in a statement. “We also do not offer advertisers the ability to directly target content directed at children in its entirety. Given the allegations, we wish the author of the report had contacted us first.”

In 2019, its parent company Alphabet agreed to pay $170 million to settle allegations that YouTube collected personal data from children without their parents’ consent.

In response, the company agreed to work with the creators of the videos to flag material aimed at children and said it would limit data collection when users watch such videos, regardless of age.

“If Google’s notices to its advertisers are true, it violates COPPA,” said Josh Golin, director of Fairplay, in a statement. “The FTC must launch an immediate and comprehensive investigation and use its subpoena authority to better understand Google’s black box ad targeting to children.”