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

I believe that this is a terrible idea. A lot of content on YouTube fall into a gray area that will have to change drastically if this law is enacted and as both a creator and a fan of YouTube I think that this law should be changed as soon as possible thank you.

If i mark my channel as not kid friendly will anything happen to me? I have a motion designing channel that i feel is going to be deleted by YouTube themselves anyways, but i want to know if motion designing will count as kid friendly. So i used about 5 songs with swear words but it isn't all of my content. I don't even swear at all. Also, i play games like Roblox and Fortnite on there too. Will i be effected if i mark my channel as non-kid friendly?

Don't let your guidelines punish innocent creators! These guidelines are overly broad and vague. If this isn't done carefully it has the potential to ruin the lives of creators everywhere.

Honestly, we understand that you want to protect children and all, but these rules are going too far. Having people being fined up to 42,000 dollars is insane. YouTube Kids is a thing, and kids can be safer on that. Instead of having insane fines and crazy strict rules, parents should have the option to determine whether their kid should have the much safer option of YouTube Kids. There should be something where parents can toggle an option to block anything that isn't child friendly, including censoring swearing, blurring nudity, etc. Although this is all my opinion, I say you should either make the penalties less strict, or having that toggling censorship button.

How about suing parents who don't supervise what their children are watching instead of trying to ruin the lives of people who mostly didn't do anything wrong and leave the Baby Shark alone.

Really think you all should clear this up specially for the crafting Community ! How can a program get this right! We use glue, scissors, paper , sewing and so on ! Why is this not the parents job or why are the parents not held responsible ! This needs to be fixed before the first of the year!

Hey so umm I just to say...YOUTUBE NEWS RULES ARE NOT FAIR TO EVERYONE! I mean come on it's not fair to everyone, there is less than 10% of YouTube audient that is 13-17 and over 90% of YouTubers audients is the age o 18 but YouTube wants everyone to make content for kids from 12 and under!

I mean come on YouTube is for everyone NOT JUST FOR YOUNGER KIDS AND EVERYONE WHO HAS A CHANNEL IS NOT RESPONSIBLE FOR SOMEONE ELSE KIDS LIKE WHAT THE HECK, Also I heard that YouTube is going to get rid of every Gacha life Video, WHAT THE HECK IS THAT ALL ABOUT I MEAN ALOT OF PEOPLE PUT A LOT OF HARD WORK INTO MAKING THEIR VIDEOS ALONG WITH OTHER CONTENT CREATORS!

This is why there is an app FOR KIDS, plus a lot of YouTubers are quitting cause of this which means less content creator and fewer viewers, plus you need to pay about $42.000 dollar for marking the content creator videos wrong or they make their content too kid-friendly or violent or whatever, SOME content creators don't have that much money.

TO ME THIS ISN'T FAIR TO EVERYONE I MEAN WHAT IF I HAVE A KID AND THEY WANT TO START A YOUTUBE CHANNEL BUT THEY CAN'T!!! Look...I'm not trying to sound upset but I'm mad about this whole update on YouTube but this is going to affect a lot of channels and this isn't fair and once again they new YouTube rules are not fair.

So I have an idea, how about YouTube stay the same as it is without these new stupid rules...

Would it not be easier to allow youtube to create a child friendly platform. And make parents sign a disclaimer that they are responsible for what thier children watch. If there was a separate youtube section for kids like they have youtube music etc so crafters could continue to post thier excellent craft vids to youtube without fear of a fine or prosecution

I have a cooking channel so Im pretty sure I'm safe, bit haven't heard anyone address cooking tutorial channels. I do have 2 video's with my over 13 years old grandchildren making cakes. They are doing the cooking, under my supervision, and they are both older than 13. Should this be marked for children because they are in the video? I'm not even a big enough channel to do ads or any monetization, which I don't know how to do any of the money making things anyways!!! My main concern os complying with the COPPA laws. I do use bright vibrant colors for my thumbnails, as I was taught to do from Think Media and Video Influencers, using the Canva app and then just on my own. Am I gonna be given civil penalties just because I use bright eye-catching colors for my thumbnails? I'm very concerned as I've worked so hard to make and upload good tutorial cooking video's, but I'm a new channel and just getting started, Because I don't make money at it yet, and use bright colored text in my thumbnails my channel could be deleted? That would be sad as Ive purchased several items with my own money for my own use on my channel, and a laptop and camera purchases I've jist invested in to make better video's and with more trendy cookware such as an Air-Fryer, and Instant Pot "type" machine to upgrade the quality of my video's and have more varied content, and now I'm afraid I spent months saving money and investing in gear for my channel and now I'm at risk of being deleted??? Because I'm not big enough to generate MONEY for Google and You-Tube at this time, I'm an unworthy content creator? This seems to then make the larger channels or channels that have been doing it for many years the favorites or only cooking channels that will make the cut? Seems highly one-sided for ANYONE whos just starting out!!! You don't get a lot of followers when your just getting started and basically computer illiterate...maybe I should quit now and cut my losses...Thank you for the opportunity to leave a comment!!! I do believe that children need to be protected, however, I don't understand why jist because your a new or small channel you just get banned...

I'm still confused about a lot of details. The biggest one on my mind is how does this work for a content creator who can't or chose not to monetize their content on YouTube. In these cases I shouldn't be responsible for marketing my videos for kids because I am not marketing. There are zero ads on the videos in these cases and I'm not collecting data on my viewers. So in these cases it's YouTube collecting the data and yet you're saying you're going to fine me for something I'm not doing? Just because my content may look like it's kid ordinated whether or not I'm marketing and/or shooting for a young audience.

This system is fundamentally flawed seeing as: This means that if kids are on the platform, their recommended would be more mature content, because kids' videos cant be recommended and child-like audio is going to cause an uproar no matter how its handled. Please reconsider this, and best of luck to anybody trying to.

does this affect content creators outside of the US?

Foreign-based websites and online services must comply with COPPA if they are directed to children in the United States, or if they knowingly collect personal information from children in the U.S. The law’s definition of “operator” includes foreign-based websites and online services that are involved in commerce in the United States or its territories.

U.S.-based sites and services that collect information from foreign children also are subject to COPPA. See COPPA FAQS B.7. https://www.ftc.gov/tips-advice/business-center/guidance/complying-coppa-frequently-asked-questions

There needs to be more specific factors. Perhaps we could just set YouTube up with something that requires proof of age to view specific content.

It’s kid content

You need to clarify what actions appealing to kids means. This could have drastic effects on the many human beings who rely on YouTube as their source of income for their livelihood.

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. Read pages 10-14 of the YouTube complaint to see the FTC’s analysis in context.

Some you tubers it is their full time job so u CANT TAKE ADS DOWN!!! I will have no way of communicating with my subscribers so I cannot make videos they will like. YouTube used to be the second largest website (next to google), but now it will die because of COPPA. Please, it was fine the way it was before!!!! Don’t change it!!!

I hate coppa I was looking forward to be a youtuber and Now I don’t want to be find 42,500 dollars

This law doesn’t really address the problem of children using YouTube inappropriately, proving their own personal information, or lying about their age. The video or content owners do not have control to collect analytics (YouTube does, Advertisers have access to the information). This law as proposed creates a hardship on the creators. Rethink the consequences.

This is great new to hear! In "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." It gives me hope that things on YouTube will be getting better!

Thanks for killing my dream on being a animator on YouTube

So if you upload only kid-directed content, you will be kicked? Just to be clear.

Please dont do this to me i make 10$ a week and trying to not go bankrupt. I work so hard and i make very little money off of youtube but just enough to buy my fam some food because the check dont hit after 2 weeks. Please dont do this. Not only will my account go bankrupt, but so will youtube

What do you mean "If it includes child actors or models"? What if I just included my baby as extra on my video that is not intended for children? Is that considered Made for Kids?

please try to be reasonable I understand that this is a huge issue and I support what you are attempting to do but this is not the way to do this YouTube changes people’s lives it gets them through the rough patches in life it lets them go to a place of pure creativity where anyone can make something and show it to the world.. but now they won’t have a way to make money even if this has been they’re job for the past few years, Gaming channels will lose everything, Animators who are just starting out will lose everything, people with dreams of making it big like they’re idols on this platform won’t even be given a chance please reconsider what your doing they’re had to be another way to fix this issue

Bro I can tell you at least 5 reasons why this rule sucks
#1 gaming youtubers can't post
#2 no one is going to use the yt kids app because it is not relevant anymore
#3 people have made a lot of money off of yt but now with this law every one is going to be broke and homeless
#4 yt will not get profit for people posting good videos
#5 its just plain out WRONG

Hello ftc i want to say please don't ruin youtube

I am begging you stop the plans of taking over youtube

This rule is very bad. It's affecting the animators and the family friendly content , if this goes on, It will destroy and ruin all the family friendly content on Youtube. Also the high amount of fine is very ridiculous, nobody has that much money to afford the fine. Instead of making this rule, You should make kids to watch "Youtube Kids" and also remove the inappropriate videos that are in Youtube Kids. Please FTC , I consider and request you to take down this rule you are making, You are making people lose their job on Youtube and loosing their money. People will be in depression and Youtube will fail if this happens. Please don't ruin one of the most important internet sites for me. I know that you are trying to protect kids but this whole rule doesn't protect kids at all. In fact, it would ruin all the contents including Youtube creators in Youtube and I suggest to kindly, take down the rule you made and make kids use "Youtube kids" instead of using the regular Youtube. I would be very happy if you let this rule down and let the creators be free to make videos and make kids use "Youtube kids" only.

Hello FTC i will politely ask you guys to stop this,many people will lose their job, they cant feed their family

Can you please clarify what type of “visual content” is considered kid friendly and what isn’t? Specifically referring to animated videos.

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. Read pages 10-14 of the YouTube complaint to see the FTC’s analysis in context.

The guidelines on what is considered "child-directed" is extremely vague. There are a lot of channels that are family friendly based on their values, but are not geared solely towards children. With the new policies being put in place those creators' livelihoods are in jeopardy based on something out of their control. In order for them to continue their passions in a way that they are still able to have a steady income, they would have to possibly make significant changes.

To have an account on YouTube you must be at least 13 years of age, so ideally no one under the age of 13 would be on YouTube's main platform unless they were given consent by their guardian. That being said, it is also up to parents to monitor what their children have access to.

There are some people who will abuse any system, but the community should not be punished for the wrongdoings of a few individuals. I sincerely hope that "The Rule" is given revisions and much deliberation. I also think that only having a little over a month's notice is not enough time for any creator to act with how unclear everything is at the moment.

Why is there no middle ground?
If there is content on YouTube that could be for all ages, why there is no option to put that content as a category "directed to all ages" or "E rating"?

Content creators don't babysit, they entertain. Implementing these rules can pretty much end a lot careers built on Youtube alone. Plus, Youtube Kids exists.

what if my animation contain something like suicide, violence and scary thing is still my video consider as "Made for kids"?

This is far too vague, and potentially harmful to multiple adult focused content creators. you don't understand young adult's enjoyment patterns. you desperately need to re-word this law.

I'm Dutch and I do not collect data I'm no big Firm that can do that...I'm a parent and I teach my child not to publicly use our adres or phone information...If a child should do it any way...I understand its dangerous and will never use it because I don't collect data anyway... I'm a single person not a YouTube Firm that can collect data. I'm a crafter and love to have children watching because it teaches and inspirer a whole new generation. But This Law is to vague and not compleet for the users of platforms like YouTube on the Web...I understand its not only YouTube it's a worldwide internet platform use...I will put for kids...But this law is not clear on anything of the content of my canal at YouTube as a crafter????

Hello FTC, im a 13 year old kid and youtube is something you just cannot change. Please don’t do the COPPA thing because it will not just affect the viewers like me but it will also affect the content creators. Many good youtubers will fail because they cannot make content anymore. My suggestion is that you COMPLETELY cancel this COPPA thing or you can just adjust this. The rules are too strict. FTC, if you somehow read this, im just helping myself and other youtubers. Im complaning politely, and thank you for reading this

I don't think that there is a single person watching YouTube who genuinely wants this to be a thing. COPPA is incredibly vague and clearly wasn't given much thought, as it completely mess with the livelihood of most if not all content creators on YouTube. The internet has gone on long enough without this becoming a thing and it makes no sense for these guideline to start now.

I would like to know if me making videos about my gothic culture is considered kid friendly. I deleted my videos to avoid any future fines as I cannot afford them. Would I need to curse in order to maintain an adult audience? I do not nor have I ever wished to target my channel to children. I am scared about the whole situation to the point where my anxiety is getting worse. I would like some clarification to at least calm down a bit.

many youtubers post some of the things you claim as “child friendly” such as animated game character, yet younger kids watch channels such as jake paul who know their audience is under 13 but post things such as his relationship with his girlfriend that include dangerous acts and inappropriate stories. how will you determine the age, and what kids are really watching? how is this not going to affect channels which use e rated games for content for older kids around 16 but use this child friendly game? the statements you claim as “kid friendly” are also used in videos made for the intended audience of 16 and above. how will you fight this against youtube while not ruining the careers and channels many older audiences love?

This is absolutely outrageous. there are countless of other ways that this issue could have been dealt with. and because of this law, millions of peoples lives are going to be ruined forever. I would rather have youtube permanently deleted than have this rule come into play. I hope that you guys can learn to see this issue through the creators eyes, and remove or at least adjust this rule to make it more clear for these creators.

why did this have to happen man i just wanna post without getting fined a fortune

FTC has to protect child content on YouTube. If COPPA is implemented, child channels will eventualy dissapear as without money no one will want to publish. That will result that toddlers and kids watch aggresive content, not related to them. The best option would be that on every channel is offered the option for parents to accept that YouTube do what it already did or not. That what YouTube did brought content creators the money for their work. So, the decision should be on parents.

Hello FTC and anyone else reading this response to the recent issue that has arisen with "children directed content". I myself have been a small creator on Youtube for a few months now and reading these new guidelines on my channel has concerned me deeply. It is true that many children use Youtube every day to watch their favorite content creators and are found in dangerous situations here and there to inappropriate content, like any other social media platform/website. From what I've read throughout all the articles, guidelines, concerns, etc. about this issue I've come to the conclusion that this statement of guideline changes is still very vague. You've given a decent explanation so far of what content creators need to look out for and what we can be fined upon but the guidelines are still unclear for some creators. These creators being the ones who intend their videos to be directed towards Youtube's standard audience of 13+, who don't curse, have animated characters, and include well-known franchises (like the gaming community) let's say like Pokemon or Minecraft. What will happen to these channels? To me, they are perfectly fine and these types of demographics are related to kids, teens, and adults. Therefore why should they put their channel into one categorized setting from mature to child-directed? I personally believe that this new rule should be removed from Youtube completely as it will destroy the platform and force content creators to find new sources of income. This new rule would also potentially make content on Youtube more mature, meaning more cursing and inappropriate topics. We all know that kids lie about their age on the internet and sometimes parents tell their kids to do this as well because of privacy issues, so what if these children come across one of these newly made mature videos? Instead, why don't we remove this new guideline in general and promote the family-friendly channels and Youtube kids then remove the inappropriate channels you don't want your kids watching. Half of the time kids don't even pay attention to ads and will just skip them entirely so I don't understand how this has become a major issue on Youtube especially since ads can be found anywhere in technology. Ads can be found on cable TV, websites, social media platforms, apps on your electronic device, a billboard sign, a restaurant/fast food joint, and even schools. Therefore I ask you please think about this decision once again before you destroy amazing people's financial services and the vague guidelines you set before us creators. Thank you for your time. - Natalie

I think storytelling from Youtube is generally not made for kids. It really relates to teenagers and young adults. Specifically, it depends on what story the storytellers are telling.

Examples of stories that AREN'T made for kids:
- A sad and/or traumatic event
- Hateful experiences
- Romance (Crushes, Break-ups, etc...)
- Toxic relationships, friendships, families, etc...
- Doing mischievous acts
- About Racism, Sexualism, etc...
- Thoughts on GENERAL things or experiences on LIFE (especially on adulthood and/or teenage times)
- Thoughts on existence
- Vlogging in places (NOT playgrounds, elementary schools, preschools & toy stores selling toys for people below 13)
- Something Unusual or Weird that it's unappealing to children (Under 13)

Examples of stories that ARE made for kids (Also according to a statement from COPPA):
- Their childhood toys, games and films (Suitable for people below 13)
- Vlogging in places (Playgrounds, elementary schools, preschools & toy stores selling toys for people below 13)

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