The problem with COPPA – Making the right choice about who is watching

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Videos made for children are now treated differently on YouTube because of COPPA – the Children’s Online Privacy Protection Act. How will Coppa affect channels with animation? Does family-friendly content made for everyone count as made for kids?

Turns out this is quite a complex issue… I try to give an overview about everything animators need to know about COPPA and what it could mean for animated content on YouTube. Just click play on the video above!

What is COPPA about?

COPPA regulates how operators of online services have to protect the privacy of children (meaning people under the age of 13). Without their parents consent, no one is allowed to collect private information of children.

YouTube didn’t care about COPPA

The big problem is that YouTube used to track as much as they possibly can about their viewers all the time: Location, watch time, clicks, IP addresses, personal preferences and much more…

Creators on YouTube are benefiting from this, because they can view detailed analytics to analyze the performance of their channel.

The collected data also enables YouTube to make incredibly good video recommendations and – of course – show personalized ads. These personalized ads tailored to the taste of an individual work much better than contextual ads just showing products related to the video content.

However, gathering all that information about not only adults, but also children is a violation of COPPA. As you are not required to log in to watch YouTube videos and you can lie about your age when creating an account, YouTube doesn’t have an effective age-gate.

Ultimately, this lead to YouTube being fined $170 million by the FTC, the US Federal Trade Comission. That’s more than any of the previous fines for COPPA combined.

What is YouTube response

YouTube is now treating any data from anyone watching children’s content on YouTube as coming from a child.

So analytics, comments, endcards, personalized ads, individual recommendations etc. will be switched off even if adults are watching said content.

It’s very likely that such videos make less money, because personalized ads are the biggest source of income for YouTube monetization. The videos can still be monetized, but the contextual ads will probably not do as well. It’s also unclear how much these videos will still be recommended outside of YouTube Kids.

To determine if content is made for kids, YouTube is asking the creators to judge their video based on a couple of factors. However, it seems like some factors have more weight than others. Obviously, animated content and cartoon characters do not automatically mean that something is made for children (think South Park or Rick and Morty).

They will also use a machine-learning algorithm to identify and label such videos. The problem is that people have a hard time making the decision – especially for content that appeals to both adults and kids.

Is my content made for kids?

If children are your intended audience it definitely is “made for kids”. For pre-school content like songs about colors or the alphabet, there is no way around labeling it accordingly.

The other determining factor is if you have knowledge that your content is being watched by kids. The YouTube analytics can be a rough orientation. Although they do not show numbers for people under 13, a high percentage in the age group of 13-17 year olds can be an indication that a lot of young people are in your audience.

But how many young viewers are enough to trigger COPPA? Ten? A hundred? 50%?

To me, this is a concerningly vague part of this law. So even if you didn’t intend to target children, your video could become a video “made for kids” based on its reception. Precautions like an age disclaimer are essentially useless to be save from COPPA.

Resources

You can read the text of the COPPA law here: http://www.ecfr.gov/cgi-bin/text-idx?SID=4939e77c77a1a1a08c1cbf905fc4b409&node=16%3A1.0.1.3.36&rgn=div5

YouTube’s original announcement: https://youtube.googleblog.com/2019/09/an-update-on-kids.html

Support article about determining if content is made for kids: https://support.google.com/youtube/answer/9528076?hl=en

If you want to dive even deeper into the topic, watch LegalEagel’s video about COPPA: https://www.youtube.com/watch?v=C3Q48dwopVU

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