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.



yknow, why do you have to either choose the two extremes, if your content could apply to anyone?

I’m wondering about the age of models. This is referring to children in videos but I don’t understand what the definition of a model or child actor is. I follow lots of family homesteaders who may have their children in videos doing chores or helping plant seeds. Are these considered children models? We have thought about starting a channel in the new year but decided against it because what’s the point of risking getting in trouble if one of our kids pops up in video. Our videos wouldn’t be geared towards kids at all mainly focusing on people who want to homestead on small average. But still there is no way my kids wouldn’t pop up here or there in videos. I don’t consider them celebrity or models or actors.

There is a app called "Gacha Life" and people use it as animation/edits called Gacha Tubers. The new rule you created says that Animation is appealed to everyone. Are Gacha Tubers not affected from COPPA?

Content creators should not be responsible for the collection of data of children. Additionally, more specification is necessary for content creators to know whether their content is "kid directed" or not. Many content creators may make videos for a certain audience rather than just an age range, such as educational videos or some gaming videos. Furthermore, the penalty of the extreme vagueness of these guidelines is unacceptable on both sides of the spectrum. Specificity is required because if not people can be punished to an unfathomable degree, because their content may be directed towards adults but fall under "kid directed". A good example is toys, figurines, or models that appeal to adults because of variable reasons. These are technically "kid directed", but really aren't, & I (along with many others) 100% believe there needs to be specific rules set & stone to avoid terrible mistakes that can ruin people's lives. I hope my comment is taken into consideration.

The problem with this is that individual channels are not websites and CHANNELS DON'T COLLECT INFORMATION. We don't collect any data from users - only what YouTube or Google tells us. It's basically saying that if you download a data set from Kaggle (a website that hosts publicly available data), you somehow collected that data set, when that is not the case for channels.

This does not make any sense - why should channels have to pay for YouTube violating COPPA. It's akin to saying since a movie on a website is playing, and the website collects information on children, the movie studio should pay for the website collecting the information.

I have family/ vacation videos that are private on my channel that contain kids. They’ve been private since the time of upload. Also, the said videos are not monetized or shared publicly.
Will this get affected? Does the Coppa apply? I’ve tried searching for answers, but have not found any.

This isn’t very fair to all of the creators on YouTube, hundreds of people will be loosing their jobs and there won’t be any kids content, this will be the end of YouTube

This vague nonsense is basically punishing commission-only "affiliates" (YouTube Channel "Owners" (not really owners as YouTube can delete them on a whim) who only get a tiny commission from the billions Google (which owns YouTube) makes from advertising) for the actions of their "affiliate scheme provider". It's ludicrous and parents should parent their kids. Well done for encouraging stereotypes of Americans as being lazy and stupid.

I have a question. If our content is like for example, a online dress up game. But as swearing and a dark tone to it, would still be for kids or not for kids?

I never intent to create videos for kids, but I or we cannot control who really going to watch the videos that I made

I'd like to address something and ask a few questions, regarding the compliance to YouTube and their terms to agree to, accessibility in order to follow the guideline is exclusive to the Computer application version of their YouTube studio, it is NOT available on their mobile application version of YouTube studio, and here's my question, as an individual creator on this platform I would like to know how this option may impact my own channel, if of course I am verified to not be intended for children, am I protected? If a video is that of just soundtrack is that applicable for the terms, and finally, are the terms still applicable to videos previously uploaded prior to the case, and last of all, does me setting an age restriction on the video, even if I did not input the general audience option, have me protected?

hello i jost whana ask can you sue me if my video is on unlisted

So how do you deal with content creator's that make content for fun without Monetization. These content creator make content so they can have fun and show products of things they can do. Some even use youtube to even get a career by posting an animation or such others things.

What about artists who make speedpaints (Process of art being made) that aren't NSFW but at the same time aren't for kids? Not all videos that look like they're for kids are.

If you upload a gaming video (Minecraft, Fortnite, etc.) will you be doing something against COPPA’s rules?

Lower the fine of which if you violate COPPA to about 100-8000 dollars. That's the only thing I want to happen.

If what the Federal Trade Commission proceeds in the enforcement of this act, how would we know all of the specifics on what is child friendly or not and that is also not described in such vague terms as the only few given right now. As in, are certain video games that are rated for an older audience but people (normally thirteen and up) play? It is still a video game nonetheless. There still is a chance children will watch it even though it is in fact very gruesome. The games being referenced is For Honor, Rainbow Six Siege, and Modern Warfare. Children play games, but is it possible that the audience it is not intended for still watches it even after certain warnings and channels being set to not child safe? Will you please explain to the creators of this platform terms of conditions or what is acceptable and non-acceptable for creators to avoid gaining a lawsuit? Some small channels, like me, have not made any revenue yet and a $42,530 fine will not go well at all. It could put several average families bankrupt overnight. Families would one have to support themselves and two have to also ration out money to pay off debt received. The gaming and every community on YouTube is at risk for severe drops in salary. Every bit of the mess could have been avoided by one, YouTube not exploiting enterprises for advertisments on the children, two, YouTube not bragging about the children, and three, YouTube not making the incorrect content coalese with the thirteen plus factor of YouTube.

What about stuff that has animated characters but not for kids like parodys and five nights at freddy's? Or those tht post gameplay of games that kids play but we curse in the videos?these lines are so blurry

If I am a child and I vilote COPPA on YouTube will I be fined

@FTC Question. How about Theme Park channels? There are 1000s of people posting Disneyland, Universal Studios Park videos with toon characters, food, rides, merchandise, etc. When adults equally watch these as kids, how would COPPA classify these? 1000s of adults have no kids and love Disneyland. Please guidelines on this subject. Thanks

I am very uneasy about the guidelines set forth by the FTC. What creator within the United States would make a video with such broad guidelines for what warrants a children focused video? "Oh you could get fined over 40,000 USD and possibly have your channel deleted." No one is going to take that gamble. I urge that you narrow down your guidelines for what contributes to child directed content. Animation can appeal to adults and children, bright colors not not exclusive to children, ext. Why is the government stepping in at all? Isn't this an issue with each individual parent who doesn't monitor their child/children enough?

If a content creator publishes a video to YouTube but disables personalized advertisements, or restricts ads from being run on that video entirely, can that video still be considered to fall under COPPA? There are plenty of people who publish their videos to YouTube for no monetary gain, but since YouTube still collects information about watch habits and geolocation from viewers, this is a point of concern.

Please review the wording of COPPA. It is too broad and ambiguous. As a severely disabled American Veteran with limited mobility, the YouTube platform has created online "friendships" for me by being able to communicate with others in a crafting community, through the comments platforms. Every age group loves crafts, but consider that just because it is a craft doesn't mean that it was directed at the crafting community we recycle or repurpose things like children's books and toys, but the end result of what happens with them is not for children. Also, our processes would be too advanced and in most cases too expensive for children. Additionally, content creators DO NOT collect data on children and they have ZERO say in the adds that play on their sites. Because a creator has a channel does NOT mean that they own the platform.
If the FTC COPPA laws make it to where the adult content is taken away, my life will be greatly affected. Like so many others, the depression and loneliness will come back in our lives. Do you understand the tragic implications of this?
Please reconsider the language of the law. Child attractive is EVERYTHING in the world. They are supposed to be attracted to everything. That is how we all learned our likes and dislikes and how to make choices.
It is time to hold PARENTS accountable for allowing their children to have electronic devices and not providing parental supervision.
Thank you

Kids should be using YouTube Kids and parents should be keeping their children off YouTube. If parents (i'm one of them) aren't capable of protecting their children's privacy and they live right there in the same house (in most cases) what makes the government think some government agency can? Ironically; the National Security Agency is actively collecting data on our children right now, who is the government too speak?

Children finding interest in something isn't a good metric to use when considering if content is geared towards kids. They are naturally curious about everything, and especially when they're looking up to teenagers and adults. Even if you currently mean well and aren't planning to take down certain things, these guidelines are far too easily manipulated and could potentially be used to censor pretty much anything on the Internet in the future.

What about channels that make no money from youtube? For some of them have a blurred range of videos.

And how will this keep children from clicking on adult videos

There’s a simple solution that people are not looking at. YouTube has already created YouTube Kids, which gives parents the power to create accounts for their children and allow them to watch only certain things on the site. To make this even better, YouTube itself might add a feature that allows parents to let their children get on regular YouTube once the child turns 13 years old. The company could even add in that by clicking “yes I allow my child on regular YouTube”, the parent is essentially giving permission to YouTube to collect data on their child. This, in turn, upholds COPPA.

As for regular YouTube, it is stated plainly in the YouTube policy (12) that anyone who creates an account must be 18 years or older, be an emancipated minor, or have parental permission to create an account. As content creators, we see this as saying that regular YouTube is a 13+ area. Whether or not the creator makes videos for children or for 13+ doesn’t make a difference. By YouTube’s own policy, creators have been under the idea that we weren’t doing anything wrong by COPPA.

In all honesty, there might be one or two creators that are gearing their content towards kids and then saying “buy my merch!” But by YouTube’s own policy, the creator’s videos are supposedly being seen by adults or children that have permission from their parents to see those videos.

COPPA is a great idea. However, in order to make it better and stronger in the 2020s and beyond, it needs to be updated. The FTC can do this by updating the “how to give permission” part. Instead of saying that parents have to send in a letter that says the company can have permission to collect data on their children, the law can say that parents can digitally give permission via checking a policy box.
To blame the creators for what YouTube did is unlawful and wrong. As a whole, creators didn’t do anything wrong. YouTube the business was the one that collected data. If the FTC and YouTube try to force creators to go one way or another on their content, creators will go somewhere else. The FTC and YouTube will be pushing “the problem” away, not solving it.

I ask that the FTC and YouTube allow parents to have the power in this situation and give creators the freedom to create. YouTube has already paid for its mistake. Now they need to learn from it and delete any future accounts that were illegally made by those younger than 13 whenever they find them. If not, YouTube will not last much longer. Don’t throw away the creators who have made you. And don’t push the parents aside. Own up to your mistakes, YouTube, and do better.

Sir mere you tube to support

What if the animation has unfamiliar characters in it like an OC somebody made?

Will the FTC every consider, requiring Youtube to have a General Audience, Kids (they do have YT Kids), options for youtube channel owners. I feel what has been categorized as for kids is too broad, although I acknowledge that usually those who have kid-oriented channels/content do usually add in their titles, descriptions and about tabs "for kids 5+, fun kids etc" so that they are able to get more tags on their videos, thus placed in more categories and leads to more views- although there is also the factor that general audience content producers should also be able to add kids and adults in the tags given it could appeal to anyone at any age. Although I understand people are upset, I feel Youtube it also at fault. They clearly violated some things and plainly ignored to let their content creators know about this, I feel the FTC should hear what the people whom are creating content are saying, and consider requiring Youtube to make more options avaliable to channel owners to mark their content general audience level and be more responsible and take channel reviewing seriously.

So what if the video is specifically made for adults, including sexual themes or explicit language for example, say if that video included popular characters or anything that coppa might determine a kid would like to see or click on, what happens then that the video was made for adults and is then marked not for kids? Do i just silence myself and delete my videos so that no one can see them? Why do you prioritize the silencing of peoples content over something as simple as having age restrictions added on videos or like television a ratings system?

Under the guidelines provided, pretty much any content that’s not the equivalent of hard-R rated could be fined, even if it’s not made for children. I don’t trust the FTC to make logical calls when it comes to discerning between content that is and isn’t targeted at children, considering how out-of-touch the current government is with my generation. For me personally, the future of gaming content is the biggest worry. Multiple statistical analyses show that the average age of video game players is somewhere in the early thirties, yet based on the FTC’s statements, they seem to consider gaming to be a ”kid’s” activity. So now I’m worried that some our-of-touch bureaucrat will fine a bunch of gaming content creators for ”violating” the law, even though they never made their content for children. These rules are poorly-crafted in that they unduely punish content creators for Youtube’s criminal actions. I hope you’ll reconsider your actions, although I have little faith in the FTC’s ability or desire to form an accurate understanding of the gaming community’s actual demographics.

You can see examples of channels the FTC considered to be directed to children in the complaint in the YouTube case.

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.

I have loved using YouTube to help build my career and wanted to share
my talents with my friends and fan. Please don't take that away from me
it means so much to me and I've been working so hard on my content throughout
the years.

Please take this into consideration and do the right thing by keeping out channels safe.

I would suggest Coppa to reconsider gaming content... not necessarily gaming content for kids... most adults also play. including Nintendo games and more.

This is horrible. I am a parent and I am beyond disgusted that the ftc is deciding what is best for my child by taking away wholesome family entertainment. I believe that the FTC is going to get a huge backlash for this. Way to keep crappy and unsuitable entertainment at the hands of every child in the world.

Okay, pages 10-14 of the YouTube complaint actually cleared things up. All those channels were explicitly stating they were for kids, or hosting cartoons whose stated target demographic was under 13.
When I joined YouTube, I thought you had to be 13 to create an account anyway?

You're ruining people's life, there's something called YouTube kids, why instead don't you just make a law which says that the parents must control their children who are under 13? YouTube won't be ruined, anything bad won't happen, remember that you're going to destroy many people's hobbies, many people's life reason, many people loves, interests, and this doesn't make sense, you should protect children's right to have free time, to live, to be happy, and you're literally gong against this.
All of you just ruined everything, and it's not like it's only in America, but it's going to affect the whole youtube.
Be ashamed of yourself.

I understand that YouTube and Google were illegally collecting info from kids, and that his law is meant to stop it, but the rules on how content is judged is very vague, and could lead to many people losing their jobs as a YouTuber. There are other ways to protect children other than this.

OK I would like to chip my thought's in. I am a YouTuber with only 28 subscribers. So that brings 2 things up. 1 I dont go for an under 13 audience. I don't know how my content falls under it since I normally play stuff like Terraria and Crying Suns and XCOM 2. How do I fall under it since technically kids could be attracted to my content but at the same time not.

Me: YouTube is slowly killing themselves, thus you're ruining the lives of millions not just because some people work on YouTube for a living, but because most of us grew up with YouTube so you're basically destroying our childhood and our escape from reality, thus our sanity all because of you, your response?

no popular songs... no colors... no sports... no pets... no games (or video games)... no popular people... no stories... no animation... no jokes.. no fantasy... no snack food or cereal... no books... $42.53K per violation... this is fine...

I’m not happy with that

This entire rule for Youtuber's content really worries me as i have very little money and could not afford to pay off the civil charges. I make mostly gaming content which is why i wish you would be more specific when describing what "Games" are targeted for children. The games that i create content on are varying from games rated for everyone to games that are for more mature audiences. It would help a lot of people tremendously if you were to go more into detail on this. Also i make ASMR content and I am not sure if that would fall under any of these guidelines. Again I ask that you look over and revise your guidelines and make them more descriptive.

I'm an autistic man, and I don't know if my videos are targeted towards kids, or not, I stopped making videos because of this new regulation, and not as many people are visiting my channel, if you ask me, if no one is visiting your channel, then it will be time to Sephiroth Meteor the channel's videos.

What about channels that comment, analyze and review animated movies and series based on image and script quality?


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