YouTube channel owners: Is your content directed to children?

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Under COPPA, how do I know if my channel is “directed to children”? Since the FTC and New York Attorney General announced their September 2019 settlement with YouTube for violations of the Children’s Online Privacy Protection Act Rule, we’ve heard that question from channel owners – sometimes called content creators. If you’re a channel owner who shares content on user-generated platforms like YouTube, read on for FTC staff guidance about the applicability of the COPPA Rule and how those covered by the Rule can comply with its requirements.

The FTC action against YouTube and Google

The lawsuit against YouTube and Google alleged that the companies illegally collected personal information from children, in violation of COPPA. According to the complaint, the companies collected that information from viewers of child-directed YouTube channels in the form of persistent identifiers that track users across the Internet, but didn’t notify parents and get their consent. To settle the case, YouTube and Google agreed to create a mechanism so that channel owners can designate when the videos they upload to YouTube are – to use the words of COPPA – “directed to children.” The purpose of this requirement is to make sure that both YouTube and channel owners are complying with the law.

A COPPA recap

That provision of the settlement has raised questions among content creators about how to determine if what they upload to YouTube or other platforms is “directed to children.” The answer requires a brief summary of some key COPPA provisions. Passed by Congress in 1998, the Children’s Online Privacy Protection Act is a federal law that protects the privacy of children under 13. COPPA’s foundational principle is one that most people can agree on: Parents – not kids, companies, platforms, or content creators – should be in control when it comes to information collected from children online.

The FTC enforces the law through the COPPA Rule. In general, COPPA requires operators of commercial websites and online services that are directed to children (more about that in a minute) to provide notice and obtain verifiable parental consent before they collect personal information from kids under 13.

The COPPA Rule defines “personal information” to include obvious things like a child’s first and last name or home address, but that’s not all. Under COPPA, personal information also covers what are called persistent identifiers – behind-the-scenes code that recognizes a user over time and across different sites or online services. That could be an IP address or a cookie when it’s used to serve targeted ads. Keep in mind that an operator also might be collecting personal information through an open comment field on its site or service that allows a user under 13 to make personal information publicly available. For example, think of a comment like this on a child-directed site: My name is Mary Jones from Springfield. I love this video!

How COPPA applies to channel owners

So how does COPPA apply to channel owners who upload their content to YouTube or another third-party platform? COPPA applies in the same way it would if the channel owner had its own website or app. If a channel owner uploads content to a platform like YouTube, the channel might meet the definition of a “website or online service” covered by COPPA, depending on the nature of the content and the information collected. If the content is directed to children and if the channel owner, or someone on its behalf (for example, an ad network), collects personal information from viewers of that content (for example, through a persistent identifier that tracks a user to serve interest-based ads), the channel is covered by COPPA. Once COPPA applies, the operator must provide notice, obtain verifiable parental consent, and meet COPPA’s other requirements. For information on how to comply with COPPA, please visit the FTC’s COPPA page for our Six-Step Compliance Plan for Your Business.

How channel owners can determine if their content is directed to children

Under COPPA, there is no one-size-fits-all answer about what makes a site directed to children, but we can offer some guidance. To be clear, your content isn’t considered “directed to children” just because some children may see it. However, if your intended audience is kids under 13, you’re covered by COPPA and have to honor the Rule’s requirements.

The Rule sets out additional factors the FTC will consider in determining whether your content is child-directed:

  • the subject matter,
  • visual content,
  • the use of animated characters or child-oriented activities and incentives,
  • the kind of music or other audio content,
  • the age of models,
  • the presence of child celebrities or celebrities who appeal to children,
  • language or other characteristics of the site,
  • whether advertising that promotes or appears on the site is directed to children, and
  • competent and reliable empirical evidence about the age of the audience.

The determination of whether content is child-directed will be clearer in some contexts than in others, but we can share some general rules of thumb. First, unless you’re affirmatively targeting kids, there are many subject matter categories where you don’t have to worry about COPPA. For example, if your videos are about traditionally adult activities like employment, finances, politics, home ownership, home improvement, or travel, you’re probably not covered unless your content is geared toward kids. The same would be true for videos aimed at high school or college students. On the other hand, if your content includes traditional children’s pastimes or activities, it may be child-directed. For example, the FTC recently determined that an online dress-up game was child-directed.

Second, just because your video has bright colors or animated characters doesn’t mean you’re automatically covered by COPPA. While many animated shows are directed to kids, the FTC recognizes there can be animated programming that appeals to everyone.

Third, the complaint in the YouTube case offers some examples of channels the FTC considered to be directed to children. For example, many content creators explicitly stated in the “About” section of their YouTube channel that their intended audience was children under 13. Other channels made similar statements in communications with YouTube. In addition, many of the channels featured popular animated children’s programs or showed kids playing with toys or participating in other child-oriented activities. Some of the channel owners also enabled settings that made their content appear when users searched for the names of popular toys or animated characters. Want to see the FTC’s analysis in context? Read pages 10-14 of the YouTube complaint.

Finally, if you’ve applied the factors listed in the COPPA Rule and still wonder if your content is “directed to children,” it might help to consider how others view your content and content similar to yours. Has your channel been reviewed on sites that evaluate content for kids? Is your channel – or channels like yours – mentioned in blogs for parents of young children or in media articles about child-directed content? Have you surveyed your users or is there other empirical evidence about the age of your audience?

What are the possible penalties for violating COPPA?

The Rule allows for civil penalties of up to $42,530 per violation, but the FTC considers a number of factors in determining the appropriate amount, including a company’s financial condition and the impact a penalty could have on its ability to stay in business. While Google and YouTube paid $170 million, in another COPPA case settled this year, the operator paid a total civil penalty of $35,000.

Isn’t the FTC taking another look at the COPPA Rule?

Yes, the FTC is currently evaluating the Rule in light of rapid changes in technology. If you would like to comment on the effectiveness of the COPPA Rule and whether changes are needed, the FTC has extended the comment deadline to December 9, 2019.

Where can channel owners go for more information?

A look at the factors in the COPPA Rule will help most channel owners determine if their content is directed to children. If you’re still unsure about how COPPA applies to you, consider contacting an attorney or consulting with one of the COPPA Safe Harbor programs – self-regulatory groups that offer guidance on how operators can comply with the law. Visit the FTC’s website for a list of currently approved Safe Harbor organizations. For more resources, visit the FTC’s Children’s Privacy page for our Six-Step Compliance Plan for Your Business.

 
 
 

Comments

This will affect countless hard-working independent creators on YouTube, children should be very well the responsibility of the parents as the site's terms themselves state that it requires a user to be 13 and older to even create an account. All this is doing is affecting the livelihood of innocent content producers.

What do I do if my videos are for ALL ages?

I don’t heckin know but COPPA happens on Jan 1st, 2020

Thanks for the clarification. It seems my content is safe.

Unclear criteria and broad brush categorization is not helpful. Animation software content provider confused how to comply. We make 3d content for expensive professional animation software and use youtube to demonstrate methods and created animation art and the content is not directed at children, however it will be appealing to some children. It seems unfair that our publications reach and feedback be inhibited with the COPPA restrictions.

This rule is too broad and doesn’t take the complexities of the real world into consideration. There is a lot of content created now a days that is meant for both children and adults, or includes something like toys, but is aimed at an adult audience. The FTC has to do a better job. Until it can, they should keep out of regulating content. Leave content meant for the ENTIRE family alone.

I already know that I'm no big shot and a single person's words rarely get heard but seriously why is this so vague and it's not the content creators fault for what adds show up except for a box that just like this bill vaguely has any options you literally have to say your 13 and up to even make a account why not just make youtube change their website so you have to have a acount to even get on the website that should fix this whole problem. Slapping a 42 k fine on a content creator will do nothing but cause drama and not only hurt the creator but the FTC reputation aswell this whole mess was made by youtube so let the company fix their problem instead of trying to scare every content creator to conform to this vague list there should not even be a for kids option on youtube, 13 and up only, they caused this let them pay for it not every little acount.

Hello! I am a bit confused here. As EVERYTHING ‘appeals’ to children. All videos. TV shows and commercials too. Walk inside the grocery store and see how-everything appeals to kids there... So let me understand this, YouTube messed up, agreed to pay a fine, but it’s now being taken out on us? We have NO control on how data was collected. We can’t control parents. It’s not our jobs. Look just scratch the entire darn platform. I’m over it!

Still TOO vague. My channel includes animation, is harmless to children (I know it's not the moral matter of the content that counts) and my goal is target anyone who is old enough to learn languages and I explain things in detailed, but comprehensive ways toddlers simply cannot grasp. As a matter of fact, not even adults understand clearly what many grammar aspects I explain means. My current age report is "55-65" meaning that my current audience is 100% 55-65 which by the way coincides with my face-to-face students' ages who need to learn in order to travel and visit relatives. I use animations because I can represent anything I want through them, unlike what my plain face in front of a camera would. I and many other creators are ruled by fear right now and I would like my channel to be MANUALLY reviewed by the FTC by someone who clearly understands Portuguese because now I and many others cannot fully trust YouTube's binary options offered without considering that kids watch "adult" content such as vehicle reviews, engineering, science, education, music, movie and movie-related content etc. The upcoming sweep is completely up to internal interpretations, so no creator will be really able to ensure they don't mean to help YouTube collect children information illegally. Is commenting, liking, sharing a video considered "child activity"? I am not against COPPA, but it requires human eyes in every video published and a report so that we have time to adjust the channel (or delete it) before we are charged a potential fine for money we don't even make. It may take several years for a creator to actually start seeing monthly cents in the AdSense, it does not happen overnight and it is YouTube who decides monetization rules, not creators.
I hope we all have a safe environment both for children and creators. I am sure most of us mean no evil at all. I will keep my channel set as "for kids" even knowing my current audience is 55-65 years old and that I create content for teenagers and adults to understand. Grammar definitely does not "appeal to children" in most cases, but I am now forced to believe it does through YouTube's binary options given. We need channel guidance from by FTC and time to remove our content from YouTube before being charged a thing. Moreover, my channel aims chiefly Portuguese speakers,

Please make the subject explicitly clear because there are people over the age of 13 that are interested in Subject matters that kids like. For example, Video Games are by not only kids but adults as well so you got to make the rules clear so people can understand. Another example is light color, adult like it is that it is generally appealing to eyes and can really get people attention not just kids. Youtube has a general term of incompetence when it come to terms and service and will use bots that are highly infamous for working and generally tend to make the same mistakes over and over when people saying otherwise. Also please change the amount of the fine because 99.9% of content creators can not pay that amount. I’m currently a beginning content creator and these rules will probably kill any chance that other small and upcoming content creators may have. So I humbly ask you can you please make the rules explicitly clear so we can be able to act accordingly.

This rule is taking away the funding for some of my favorite YouTubers, they will not be able to fund new videos and they will not be able to support themselves. It will negatively affect them as individuals, content creators, and us as viewers.

There still needs to be clarification. A few topics that need to be clarified.

Sports: on the original release taking about COPPA it listed sports as "kids content". How? Sports are made for everyone, a youtube channel taking about professional sports shouldn't be considered as "made for kids". I could understand if it was a peewee team or midget hockey, leagues that are U14 but not NBA, NHL, MLB, NFL, MLS, or any sport that has players over the age of 14.

Video games: this is probably the biggest topic to be talking about. What video games are co sided made for kids? How do we now which games are made for kids? Is it the rating on the game? But then what if a game is rated E? Then that means it's for everyone, and so should not fall under "made for kids". If it's the subject matter then what about video games about superheroes? You could argue that a game like that is made for kids, may even have an E rating, but contains violence, the most non-kid friendly content out there next to sexual themes. Then what about a game like minecraft? It's made for everyone and people of all ages play the game, and enjoy watching videos about it. This needs to be incredibly more transparent.

And what about pop culture? What of pop culture is considered made for kids? Star wars? Contains violence. Marvel/DC? Again contains violence, and mature themes. What about rick and Morty? Its animation but is definitely not made for kids. Simpson? And what about lego? If someone is doing a custom build on historic buildings, or buildings from pop culture? What about vehicles or characters from pop culture? What about lego architecture? The list goes on and on.

As for the comments section, you need to create an account which states that you must be either over 13, or at least 16 years of age (forgive me I dont recall the exact wording), for precisely the reason to follow COPPA. If a child lies about their age, it isnt the content creators fault, its either the fault of youtube for not screening, or it's the fault of the parents for not parenting.

Let me ask you this, if a child walks into a movie that's rated 14A, and the child is 13 or below. Os it the directors fault ( on this case the content creator)? Is it the cinemas fault ? ( or in this case youtube) is it the fault of the parent? Undoubtedly it's the parents fault.

Why will you fine content creators who do not collect data on children, when it is youtube that does that. Owning a channel does not equate to a website or web service. It's more akin to to a producer, and director of a movie. YouTube is the cinema, that makes money off of the work of others, and in turn the movies make money off the cinema. The FTC should go after youtube, not individual content creators, again individual content creators are not collecting data from kids, the youtube is.

I worry that the crochet , sewing, homesteading, gardening videos I watch daily will be affected by this. These channels teach different things that could appeal to children, but are not made for children. I started crocheting and sewing at 9 years old, so I could see that would appeal to some. I don't find these videos harmful to children at all. It's teaching a skill that is useful. To put the pressure on content makers instead of the parents is not right in my eyes. Parents need to be held responsible for what their children watch. As a parent I didn't let my children watch certain TV shows, and none were allowed a phone until 16 years of age. None had access to a computer except at school. Which made it hard when teachers gave homework that involved using the computer. I controlled which movies they saw and so on. Content makers are not here to make sure your child doesn't watch their videos, that is the parents job. So to fine the content makers is wrong on so many levels. There needs to be a box for content makers to check that this video is geared towards adults. To much left in the unknown area.

YouTube was originally a dating site before it became a place to create videos and upload them for fun. By this time it was intended for the little guys to have a chance to be successful. But now it has become extremely difficult for smaller channels to succeed since YouTube set their standards so high for the partner program with needing to have 1,000 subscribers and over 4,000 watch hours within a 12 month span. Then when you have reached that mark your channel is audited and "fake" accounts subscribed to your channel are removed and after that you no longer qualify for the partner program and you have to start all over again. It is very discouraging at times. Now COPPA is being put into effect and it will make everything even more difficult and extremely discouraging. There is a massive community out there that have Reborn Dolls that are not meant for young children they are considered works of art and are collected by ADULTS. But COPPA wont see it that way. Please reconsider this rule as it will create a massive negative impact on MILLIONS of people. Instead of going through ALL the accounts on YouTube target just the ones being produced by kids ONLY not the adults. For a lot of people YouTube is how they make a living and it's their only source of income... PLEASE PLEASE PLEASE reconsider this rule. TIA

I know that some videos contain swearing and sexual content and plenty of kids are watching this but that dosent mean you have to make a rule about this if anything it's the childs fault for watching it and some parents are complaining that YouTube has all this sexual content and other things but if you think about it kids shouldn't have been allowed to use YouTube in the first place Im not going to blame the content on YouTube im blaming the parents and children I recommend you to get rid of this rule and just ask people to delete any sexual content and for swearing you could ask them to bleep it out but this is only my opinion

I'm going to lobby my congressman to fire everyone in charge of the ftc

Hey I personally don’t think that this is fair considering a lot of stuff that this will basically get rid of is also stuff that is popular amongst autistic people, many of us take on a special interest that we love focusing on that falls under some of these categories, many of us color stem and like watching stuff that we find visually satisfying, many of us use these videos to calm down on our rough days in order to better fit in to a world that is more suited to people who aren’t neurodivergent. By doing this less videos will be made that cater to us and many that are will be taken down or put away where we can’t easily access them. Please please please reconsider, both I and my feoncé are autistic adults who will suffer from this decision, all I ask is that this is re-evaluated with Autistic people in mind, thank you for your time.

It is the parent's responsibility to manage what their kids are watching. Not the content creators. This is a prime example of things never being the parent's fault, but someone else's. This is not how this should be handled.

Yes, thank you.

This enforcement will now encourage content creators to be more vile in their videos just to make sure it’s not child directed. This makes it hard for creators who do crafts and such. I sew, none of what I sew is geared towards children and yet there are children that like to sew or are learning to sew. Why are the creators being penalized and the parents are not raising their children or giving consent to their children on YouTube when they hand their devices over to them. Why not put parental blocks on YouTube so the parent can block videos and such? It seems more of big brother trying to dictate what the creator is allowed to do and taking the responsibility off of parent s to parent their children.

Sorry, BUT. You forget that YOUTUBE KIDS EXIST. I mean its parents fault. I never got an account until 11. WARM PARENTS DONT RUIN YT.

My question about this is, where does the line fall. What subject matters are going to be overly targeted, what music would you target? What would this mean for the smaller content creators, that don't make money, that have less than 1000 subscribers? What does this mean for content creators that return to YouTube in 2020, after a long hiatus, and have no clue what to do??

I have so many questions and not enough answers.

Please stop this
I don't want my favoriye channel gone over night

There is no way to actually protect children from adult content. Even before the internet you couldn't. There was no way to censor a person in real life jumping out of a vehicle, which is burned into my memory. So what is the real point of this? Just to make an extra buck in your fat pockets? To censor and oppress creativity and imagination?
I get that YouTube collected data on children, is that what we're trying to stop? What kind of data? For targeted advertising? And what harm is targeted advertising? Is it location data? Is the data sold to child molesters? Are children being molested because of data collection? What is the harm in the collection of data? What prompted this whole thing?
Originally you had to be 13+ to have a YouTube account. I know those younger than 13 can LIE but NO ONE can control that. Quit trying to control things you cannot.
Also, FTC, you really need to re-evaluate your definition of "child content" Actually look into today's media besides news and politics and business, look into the creative side of things. Creativity is not just for children, it's for adults too. It's for expression of your inner self. Your SOUL, if you will.

I mean, if YouTube Kids exists and parents choose to use YouTube over Kids, then it's their fault. At least tell YouTube to fix and patch up YouTube Kids. One suggestion may be to have YouTube only available to people who have an account, and have guests only given the ability to see child-friendly videos. Hope you take account into all our suggestions.

This is stupid it seems like your higher-ups are being paid off by cable companies because YouTube's becoming a threat to their profits I think you should be investigated for corruption

I am an Autistic youtube content creator whos channel is more geared towards young adults and even adults, so this is very confusing for me.

And what i would love for the FTC to do is to try and help content creators like us because my content has already been censored or down right hidden by the youtube algorithm because of the content i produce. So i ask that if its possible that the FTC take lead on this instead of COPPA or at least address in detail channels that are more oriented towards guns, combat sports, and other more Teen to young adult sports like paintball and airsoft.

Thank you for your time and i wish for the best of luck for everyone.

I think everything that needs to be said has already been said, COPPA is just bending the knee to easily offended individuals who just want the world to be censored. If this law passes, YouTube will officially be dead and will be as abandoned and toxic as Chernobyl. This can't pass and if it does, there will be severe backlash that will never stop until the law is repealed. YouTube has an app for kids, but nobody acknowledges its existence. To sum it up, these people need to grow spines or not use the website, simple as that.

How to even direct as to whether it's for kids or not is the problem now because I'm trying to upload and yet YouTube is not permitting me

So, my ideas: 1 a lot of people will sign up for google accounts and state their age as older than they are.
2 There's already a Youtube Kids.
3 Kids will watch whatever they want to, they can just make a fake account (like i mentioned above)
4 It puts too much hassle on us little creators, who already have targeted censorship aimed at us if we say something that may be offensive(BUT IS NOT INTENDED AS SUCH)

Please If could just add it to the sittings if you are to upload a video then you tab on it to select
# for kids
# for adults
# both kids and adults
It's would help because I'm finding it so difficult to upload now

Who remembers YouTube Kids?

Please just remove this. This will be terrible for all of youtube and achieve the opposite thing you want to happen. On behalf of literally everyone on youtube or watch youtube. TAKE DOWN THIS RULE

This is ridiculous and over exaggerated. Why should everyone on a website be affected for something they don’t do? Why should they be limited to the things they created? That’s a violation of the First Amendment because people can’t express themselves in videos anymore since it’s now regulated with vague and confusing rules that are supposed to “protect children”. While there are many channels that create videos for kids, not all channels on YouTube are meant exclusively for children. An easy solution would be to make YouTube have a parental control setting so that parents can monitor their kid’s activities and data on YouTube. This easily solves the problem of protecting children, as a guardian is now watching over them, and it keeps current and future content creators safe from all this unnecessary “laws” that could potentially affect them negatively. Please rethink this “regulation” and take into consideration how the numerous amounts of content creators will be affected on YouTube for following guidelines that aren’t directed towards them.

I believe that this COPPA thing is really unfair to YouTube content creators and to all their viewers
Lots of popular YouTube channels make people laugh and help people through some really tough times and even cure depression, I know that from experience
If the viewers lose their favourite YouTube channels then some depressed fans may lose hope and feel even worse

This ruling has the chilling effect that anything targeted at a "general audience" is going to be marked as "appealing to kids" because of how broad the description of 'for kids" is. This needs to be reconsidered, as it is going to destroy Youtube, and other monetized video platforms, and force content creators off of these platforms.

To be clear here id never be able to pay just about any of the fines here the reprocussons could put me on the streets homeless. Coppa has no business in all this when there is such a thing as youtube kids and im sure that standard youtube fate is grim if nothing changes. Most creators like myself again could wind up on the streets homeless or in severe debt all for something as simple as a minor mistake.

This blog post was not helpful to me. To many "may" and "possible". The language is still vague and there are still questions without answers. I question the statement "COPPA applies in the same way it would if the channel owner had its own website or app" because according to Title 16 Section 312.2 of the COPPA Regulation, 'Operators" is defined as someone who operates a website or online service that collects the data. Youtube is that website/service and content creators are unable to collect data.

We also need address the matter of content creators who don't make any income on youtube and never used monitization. Hobby creators make up a large number of channels.

The FTC FAQ's also seems to lead that COPPA would not apply to websites that are for a general audience. Youtube Kids is absolutely covered by COPPA. Majority of the channels and content on regular youtube appeals to everyone, so Youtube (the operator) should be stepping up and providing better tools to content creators to accommodate this, "for kids" and "not for kids" is not adequate, and the third option of "General Audience" should be added. the Age Gate would go so far as to solving this issue.

You mention part of the definition of "Operator" from the COPPA Rule. The FTC's Six-Step Compliance Plan for Your Business explains that COPPA applies to operators of websites and online services that collect personal information from kids under 13. Here’s a more specific way of determining if COPPA applies to you.  You must comply with COPPA if:

Your website or online service is directed to children under 13 and you collect personal information from them.

OR

Your website or online service is directed to children under 13 and you let others collect personal information from them.

OR

Your website or online service is directed to a general audience, but you have actual knowledge that you collect personal information from children under 13.

OR

Your company runs an ad network or plug-in, for example, and you have actual knowledge that you collect personal information from users of a website or service directed to children under 13.

Here's the deal.
Channel owners do not use YouTube to collect data on anyone, let alone children. They have no control over any data tracking or access to the info YouTube collects on its users other than generalized analytic graphs of audience pools. YouTube is not gathering information at the behest of channel owners. YouTube gathers user information for itself and itself alone.
So, while content creators are mercilessly thrown under the COPPA bus, it's business as usual and YouTube happily continues accumulating user data. Let's be real here, we all know its not as if kids under 13 are going to stop lying about their age to make online accounts and watching videos that were not intended for children.

Watch YouTube for an hour, then go back to read what was wrote in COPPA. Innocent and even helpful people's Lives depend on not implementing COPPA. YouTube has already taken step to prevent the worries in this.

i have seen your email and would like to say... No my content is not for kids, sure i have plush videos but... Take my Kirbys Adventure pt. 3 it involves use of fake cocaine (its sugar) and that may not be suitable for children. I only have 110+ subs and i doubt many kids watch my content. Again, my content is not for kids. I hope this confirms my non child friendly content.

Parents should be the ones responsible for what kids see and do on youtube, not the content creators.

Sooo how long will “COPPA” last, will It be forever?

This is stupid. Plain and simple.

I understand children's online privacy needs to be protected, but a $42,000 is excessive. With only vague instructions for determining if content is child-friendly or not, infractions seem very likely. And one minor infraction could cause a fine so large it permanently ruins someone's life.

The "Made for Children" or "Not made for Children" is too vague. I'm still in a gray zone. Some of my content is friendly, some of it is not and most my audience are women between 18 and 35. For who my content is made for? You have only one solution, create a third category: MIXED UP AUDIENCE!

it is not youtubes fault that kids use the app for grown-ups, thats why theres youtube kids, please ftc think about what you are doing

great to see you’re more lenient with us than we thought

now if only you can tell that to youtube

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