Data concerns: YouTube under fire from child advocacy groups

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In a week swirling with news regarding privacy concerns, an alliance of child advocacy and privacy groups have filed a complaint with the Federal Trade Commission against Google. According to one of the groups Commercial Free Childhood, the complaint was filed on April 4, 2018. The complaint alleges that Google is violating the Children Online Privacy Protection Act, which requires parental consent prior to data collection for sites that are aware of children using that site. The document claims that YouTube is aware that children regularly access the site based upon public statements by its own executives, disclosures and of course the creation of a kid friendly app. It also notes that the second most popular channel on YouTube is a channel for children. YouTube makes money off the ads on the site and the data collected from viewers is used to create profiles. These profiles are then targeted with ads that are tailored for that user. The complaint also points out that YouTube in fact does not have a child privacy notice posted on its site. There are directions for creating kid-friendly content but that does not keep the content from being posted on the regular site. 

What sort of data can be collected? 


The complaint cites YouTube's own privacy policy and claims that even without an account it still collects data. They claim that according to the policy, YouTube collects geolocations, IP addresses and persistent identifiers. Persistent identifiers use different information such as IP addresses, device serial numbers, customer numbers in cookies and other bits of information a user transmits to identify that person as a unique user. That user is then targeted by ads for which Google receives large amounts of money. According to the protection act in question, collecting this data means a company needs parental consent if they know children are the users. 

So, what will these groups hope to gain? 


The documents filed with the FTC are requesting future compliance oversight of Google by the FTC as well as civil penalties. The act allows up to $41,484 per violation and the complaint cites sources that say over 75 percent of children between six and twelve use YouTube. If Google were found to be in violation of the Children Online Privacy Protection Act, the damages could be enormous. The coalition is seeking tens of billions of dollars in penalties which they say will deter any future wrongdoing by the company. It remains to be seen where this complaint goes and what the outcome will be. 


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