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

Help me please

There must be a positive healthy way for platforms like YouTube conduct business without the need for anyone's data collection and contextualized ads seems to be the best and safest way. It seems to have worked with TV and the internet has the advantage of having shows accessible anytime from virtually any device today. Data collection is dangerous not only for children, especially geolocation information and people's names.

But there are a few reasons why this should not be a thing like content creators make a living off of these videos and doing this is like saying “look I’m not gonna kill you just shoot you in the legs” and it’s not the content creators fault that parents aren’t monitoring what their children are watching and lastly you are killing a platform that is huge and not to mention the fact not all of these are only things that kids like adults like Pokémon adults like animation too

look's like i'm going to jail because i uploaded a video to youtube.

My hobbies are not just for kids. I love toys, I love games, cooking, art, crafts and a ton more things that this will wipe it! Let parents be parents and make kids use YouTube kids! Punish youtube, they broke the law not us!

it’s not the creator’s fault that kids are getting exposed to mature content, it’s the parent’s faults for leaving their kids unattended on the internet. ugh

I'm still wary about using YouTube after this. I just want to make it clear that many people above the target age of certain shows watch thise aforementioned shows.

Attacking the youtubers is not the way to go, as it is not their fault that the platform itself has been breaking the law. Furthermore, you have to be 13 years or older to sign in to YouTube, making this even more invalid.

This is vague and doesn’t tell us what is too child appealing and what isn’t. It isn’t easy to wrap ones head around, even more so as it is judged by humans. Humans have varied opinions and don’t think the same way. If it was judged by bots, everything would go horribly since AI will most definitely mess up.The margin of error on both sides is gigantic so many do not think this is the right way to go.

i don't think that the fine should be 42,530 dollars this will destroy and ruin lots of family's because they don't have the money this will also destroy YouTube i seen many people quit their channel because of this law please reconsider this.

This needs to stop I’m not sure you’ll read this but understand that some of my favorite YouTube channels are at risk who will I watch if this happens? Please understand that this is a website for everyone
I just hope you understand

Dear FTC,

Please stop. Or at least listen.
I understand that your business is the protection of children, but to start off, this is *not saving children.* This is harming the entirety of one of the largest companies on the face of the globe. A huge, huge majority of content creators are designed to entertain ages of 13 and up, and we cannot protect any children from seeing those sights, as they *will* lie and they *will* reach the video. Your method, rather than a hopeless jump at protecting said lying children, is harming and ending countless channels in the near future. While the COPPA rule is certainly important and helps the privacy of children all over the world, this is still putting stress on people who do this for a living. There are people who live solely on the ability to create content that generally all ages can enjoy. This harms everyone. And no content creator on that site is responsible for the children you keep trying to protect by harming our providers and consumers.

Let's say I'm a child. Let's say I'm 12 of age or under, and I chose to look at a youtube video because I just *want to.* I watch the video. It has profanity, but it also had things that could potentially allure me. Is it my fault I clicked on the video, or is it the content creator's fault for developing something that could allure to children?

The answer is, it varies. A child can only see the content of a youtube video depending on the *thumbnail of a video.* Previews, thumbnails, and video titles are what can attract a child. What the system needs is not a strict and undeniable rule that will make all content gray, but rather, a warning and labels you can publicly view on the thumbnail on a video. Allow me to explain.

This system is going to be exactly what you're looking for in terms of efficiency, as the children of today are clearly not going to obey the oh-so loose rule system of youtube as of now. We need labels to observe and display when creating content that anyone could see in a preview before playing the video. This could be seen by tapping or clicking the video and seeing labels selected or made by the content creators. If there's an overwhelming percentage (>50%, likely relevant when video obtains 1,000+ views) of reports on the video with a new report reason, "Improper label warnings", there should be a warning sent to the producer of the content about the videos, and if not re-labeled within 48 hours after detecting their profile being active, should have the content forcefully labeled or removed.

That's all I need to say for now. Your method is forceful and harmful to the many creators of this website, and nobody is going to let you enforce this without making a bigger hole for everybody to fall into unless you do it right. That's no threat, that's a warning.

My privacy is asked. Thank you.

What about if you'r not sure about your content can you just set it to "Not For Kids"?
because I don't want to upload anything because i don't wanna get my parents a 42k fine.

YouTube as a site is 13+ and if you are under 13 you have to agree to it term and services. So we know that kids watch normal youtube but if they are using the "normal" version then that means that they have their parents consent and if they don't agree then there's youtube kid a app dedicated to kids and kids video That means that it shouldn't and that all the videos made for kids should be put on the kids site and the ones made for 13+ should stay on the normal site. There is a part that is mixed which means that a wide range of audience can watch that should be put on both websites/apps. It's just my suggestion.

Hey I have an idea what if when you click this video is for kids or channel is for kids why not remove that channel off the main youtube platform and put it on Youtube kids I hope this helps and yeh

While I believe that we should all work to protect our children, I am very concerned that many of the creators I watch will be targeted because they are about arts and Crafts. This would seriously effect my life as I am disabled and these videos bring me joy and an outlet for my own creativity. Turning off the comment section doesn’t allow the viewers to ask questions or get answers. It also doesn’t allow the creators that do this time consuming job for free to be thanked and encouraged for their efforts. Please take into consideration all the people who benefit from these videos and discourse. Clarify the language or allow for a mixed audience classification. Thank you.

These rules are incredibly vague and most YouTube content contradicts itself with these rules. For example, I play legend of Zelda breath of the wild, a game which by all means is appealing to kids. Which means for kids right? NO, because I drop multiple F bombs on occasion and talk about subjects not suitable for kids, which means it's for adults? Again, no, because it's still a game appealing for kids. No matter what option I choose, I'll break a rule and despite the fact that I make no money on these and don't collect any information I'm going to get fined for more money than I could possibly afford? That's another thing, I'M NOT COLLECTING INFORMATION so how can I possibly be breaking the rule, YOUTUBE collects information, not content creators, and we have no access to that information. Stop threatening to come after us for a rule we're not even capable of breaking.

Under Step #1 of the Six Step Compliance Plan for Your Business, 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.

“Excessive bail shall not be required, nor excessive fines imposed, nor cruel and unusual punishments inflicted.”

That's the eight amendment. Now I don't know about you, but any fine to a creator that does not make any money of their videos is in excess, let alone anywhere in the fourty thousand range. Also what do you intend to do to minors who create content on YouTube? You only have to be thirteen to have an account, so what if some fifteen year old kid breaks coppa? You just going to fine him or his parents some amount they can't possibly afford?

More detail needs to be put into these rules. The implication of the rules you have defined here as a "catch-all" will ultimately destroy the livelihoods of many content creators -- You want to talk about taking away jobs and livelihoods? Enforcement of these rules with a ludicrous fine is certain to dissuade any future production of anyone wanting to animate, video tape themselves and want something more beyond simple views and likes.

It's difficult enough that content creators on Youtube have to deal with extremely arbitrary rules which include the abuse of copyright strikes without having to go to court to defend themselves; remember that there are hundreds of other creators below the named individuals that come to mind when talking about youtube personalities that do not have viewer or subscriber counts in the millions to live comfortable on revenue earned via ads-- and their aspirations for success will likely be beyond grasp should COPPA be enforced.

Other alternatives needs to be explored if COPPA is something the FTC wants to apply -- provide warnings if a user is below the age of 18, have parents have an account linked to their children's to monitor their activity, teach parent's to be responsible and discuss what they're watching and what they are and are not allowed to watch!

Ads have been around forever via newspaper, Radio, television. We see them everywhere, and those companies are still wanting to buy ad space in the internet realm. If you insist on limiting targeting ads in one aspect, then consider going all out and targeting billboard, television and radio -- imagine the Economic implications of such a rule enforcement: Everyone Loses.

If any politician has the Chutzpah to read any of this -- understand the dissent is real. Reconsider COPPA. or better yet: Redefine it.

these vague laws won't help it's the parental responce is the real problem but i do think that the curse/ inappropriate language or bloody or gorey/some types of anime should be blocked for an under 12 audiance is a good thing but fining someone 42,530.00 dollars that's insane. you should contact parents before allowing anyone under the age of 13 use youtube.

Pls, don’t this, I HAVE ENJOYED YOUTUBE SINCE I WAS ONLY 5, and I’m sorry that I’m shouting but pls, I don’t want you to ruin mine and all the citizens number one childhood app, YouTube is so amazing and all the YouTuber’s I watched are really amusing and funny but when years have gone by, their channels are starting to drop on lack on content because of YouTube’s rules and standards but PLS, this is going to far and I beg of you, don’t do this to ruin all of are childhood (I guess??)

This is the stupidest thing the FTC has ever done. The fact that some of these family friendly content creators are gonna lose their jobs due to this is so ridiculous

I don't understand if Gacha Life or Flip-A-Clip is kid friendly. The audiences are mixed and don't always stay directed to 1 side.

Fnaf, bendy, and other types of games tend to attract children what is there difference? Also thank you for reconsiding your idea for your YouTube.

The rules for COPPA are extremely vague. While it is good to have new info about what creators will and wont be fined for, it feels unnecessary to punish creators for making content that appeals to children in one way or another. The best way to fix the issue isn't for the creators to handle. Its YouTube and google that should be at fault. Its like parents having a fight in front of their kid, but instead of being civil about it they, instead, decide to beat the child. YouTubers cant really do anything to defend themselves from YouTube's demonitization much less COPPA. To tell the truth, the best way to fix the issue AND be compliant with COPPA and let YouTubers keep going how they are, is to make a mixed or for everyone option. Lots of different people like different things and nothing is black and White. Another thing to add onto that is to have YouTube make an option to turn off personalized ads. Not only for kid accounts, but for all of them. That way any parent who lets their kids watch normal YouTube will not have to worry about data being collected and YouTubers who also have above 13 year old viewers can still get enough money to keep creating. If this issue doesn't get fixed im afraid YouTube kids will stop existing, and the content creators are allowed to make will just deter viewers. Because of demonitization creators cant make content that mainly appeals to adults. No cursing sexual themes or heavy blood/gore. But on the other hand they cant make things too appealing to children. No language or themes like frozen or other things kids like. Not even pets... It puts creators in an uncomfortable box that many will just back out of and quit. So I ask you now, please consider these options, else the fall of YouTube as a whole will be upon us soon...

Thank you for reading my opinion.
A concerned viewer

What about anime? Anime is colorful and animated and some have bright music, but not all Anime is geared towards children. Like there's many animes out there that have blood, gore, adult language and partial nudity would those channels be taken off of YouTube or the people gonna be fined??

So wait?? YouTube is going to put 18+ ads before content if it's deemed not for children? If I want those kinds of ads, I know where to find them. As a viewer I have no desire to see them and kids are still going to watch YouTube regardless of whatever stupid restrictions you put in place. As a family friendly creator, I refuse to support YouTube and the FTC in censorship by telling me and my family what I can/can't watch and discrimination by rewarding content creators that are "edgy" with more ad revenue.

Youtube was already hard enough to upload onto, with demonetisation and all, but THIS??!! this is uncalled for
What about educational videos? They have animation and moving objects such as animation, and vibrant colours
You are not protecting the kids you are taking away all the things they come to YouTube for, you are removing people's jobs without them having any kind of say, and the fact that it's not their fault, that parents don't monitor their kids
I also do not understand how a gaming video is going to affect a child's privacy especially if it's a non-commentary channel
Not to mention animation
Animation is hard work, taking weeks, months YEARS even, and with these silly rules, they won't earn a single penny for their hard work, please reconsider adding this rule to YouTube as nothing was wrong before, what you are doing is equivalent to blinding a child deafening a child and locking them up in a Tiny room, You are putting them in a small bubble and not letting them have freedom on what they would like to watch, and there is YouTube kids. It's the parents fault for not "Protecting their child" Not content creators. So reconsider this please.

I dont understand why COPPA is applied to you tube. How do you even know if it's a kid or adult watching the video how do you collect data on kids when you dont know if a kid or adult is watching.. Its parents responsibility to ensure their kids are not disclosing any personal info. I have no problem with my child under 13 watching videos on you tube. Teach them to watch not comment, problem solved. I could care less what ads pop up. Ads are on TV and lots of them are geared to kids so kid friendly channels should have ads. There should be parental control on you tube to block kids from commenting then there would be no issues, remember it's the parents responsibility to police what they watch etc. Not the FTC.

I have a YouTube channel that people ages 18-24 watch. No children have ever been on my channel. I hope I don't get effected by the COPPA rule. Please reconsider the rule. I don't have to money to pay any expensive fines and I don't want to risk losing my channel. Thank you for taking the time to read this comment.

Is this seriously it, or is there somewhere that gives more detail on what "visual content" is ? I mean seriously if theres not, then this needs to be taken to court for the ambiguity of it so that we can get clear guidelines down to the letter, cause that's how complex this situation is, you cant possibly think "child-oriented activities " is an acceptable guideline, it's nowhere near clear enough.
I mean I quiet honestly think needing to establish whether your content is for kids or not is ridiculous in the first place, as it's a parents job to make sure they're watching age appropriate stuff and not the creators.

Follow the links in the blog for additional information.

What about travel vlog of a family a mother father and daughter is it under coppa? It is a family oriented channel

i love youtube and i don't want favorite youtubers to go away because they mean so much to me because i don't know what without them. please save them and don't change youtube.

Just because content appeals to children doesn’t mean it’s for children .There are movies , video games and shows that appeal to children because of (for example) the fact that it is animated .It isn’t the creators fault that a child decided to watch their video that isn’t for them unless the title or thumbnail says something like ‘for children , for under 13’s.’ It isn’t the creators fault what they made is acceptable for children and/or is appealing for children ,especially because what topic children like changes. Therefore the creator should not be punished with a fine, nor lower income. Instead the parent should be held more accountable, you shouldn’t have to parent children on youtube.

I have a YouTube channel that is primarily about animation. The rules about animation are confusing.
If the animation has a dark subject matter does it mean that it is "not for kids". What if the FTC mark a video with a dark subject matter as "for kids"?
Are animation memes safe? I'm really scared for the future of my channel.

The FTC is not labeling content on the YouTube platform.

You seriously need to rethink this approach. If only google would make it harder for kids under 13 to actually use and login to youtube, then there would be no problem at all. Now you've only let all content that is considered "for children" to be really hard to find. Now children cannot even search for content that is actually intended for them. All chrilden will simply end up watching more adult themed videos because of this stupid decision. Congratulations. An approach as stupid as this can only come from America. Casper, Denmark

what kids watch should be responsbility of their parents not the fault of the platform or video creators. this is very wrong way to get things solved you ruing the creativity of people that worked too hard to build their channels and passion..kids do watch everything no matter what. small example they watch real garbage trucks not toys but real cars they put away garbage. would you consider this as video kids content?? of-course not.. but here you are kids do watch garbage trucks.. so lets say i create video with real garbage trucks how would i mark this kind of content for kids or not.. so thats an example for you to see that there no real tags whats meant to be for kids,,they do watch everything and this new rules will destroy the whole idea of creativity on you tube

Why are you seeking to penalize crafters who are sharing their art and helping others to learn how to do it. Family friendly channels where homesteaders share their home and families with us and arts & crafts channels that share people's collections and how-to videos on repairing or changing fashion dolls should not be blamed if children watch them...why not use a system of warning parents like movie and tv ratings do now?
Just a thought, but it might save some people a lot of grief and money...please be more plain-spoken with your current guidelines...

How has this not been stricken for vagueness?

My channel is safe for children

I do not have a YouTube channel. But I watch tutorials, music and how to fix stuff videos. I personally think that YouTube is throwing Their content creators under the bus and avoiding their culpability and responsibility to comply with COPPA regulations. Their solution is vague and difficult to follow making the content makers continue on a wing and a prayer

Why not just demand that YouTube/Google comply with the law and stop tracking children, rather than put the onus onto content creators who can't control what is or isn't tracked?

This "made for kids"/"not made for kids" nonsense isn't helping anyone. Let people make content for whoever they want to. Make YouTube/Google be responsible for not tracking kids since they're the ones so hellbent on tracking people in the first place. Content creators in large part just want to make content that people enjoy without the looming spectre of financial ruin for checking a checkbox the wrong way.

Please push YouTube to add a 3rd 'wider audience' option for content posted to the site. "For kids" and "Not for kids" are extremely vague and do not fit most of the content posted to YouTube. I understand this move is to protect children and their privacy but this is hurting so many creators, their livelihoods, their families and in turn their children.
Please also amend your guidelines on what "child directed" content is as this is causing much confusion for YouTube, I have watched countless hours of other creators trying to understand and summarise these policies and they nor myself know if we can continue with our channels due to these changes. Please provide some clarity.

The FTC shared some general rules of thumb in this blog. Unless you’re affirmatively targeting kids, there are many subject matter categories where you don’t have to worry about COPPA. 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.

The complaint in the YouTube case offers some examples of channels the FTC considered to be directed to children. 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. Many of the channels featured popular animated children’s programs or showed kids playing with toys or participating in other child-oriented activities. Read pages 10-14 of the YouTube complaint to see the FTC’s analysis in context.

can you lot not ruin youtube please? making it so you must choose if your video is kid friendly or not kid friendly is wrong YouTube creators should be able to do what they want without being scared out of there minds of being fined 4 million for saying there video isn't kid friendly and you lot say it is. Kid friendly content won't even be a thing if you lot do this because they will lose 90% of there revanue so what would be the point in even doing YouTube if you don't even get payed for the effort you put into your video that's kids friendly. Please change this and make it fair for everyone one make it fair for every YouTube content creator

Please look at the blog again. 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.

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