By | July 10, 2023
YouTube ads may have led to online tracking of children, according to research

This year, BMO, a Canadian bank, was looking for Canadian adults to apply for a credit card. So the bank’s advertising agency ran a YouTube campaign using an ad targeting system from Google that uses artificial intelligence to find ideal customers.

But Google, which owns YouTube, also showed the ad to a viewer in the US on one Barbie theme children’s video on “Kids Diana Show“, a YouTube channel for preschoolers whose videos have been viewed more than 94 billion times.

When that viewer clicked on the ad, it led to BMO’s website, which tagged the user’s browser with tracking software from Google, Meta, Microsoft and other companies, according to new research from Adalytics, which analyzes ad campaigns for brands.

As a result, leading technology companies could have tracked children over the Internet, raising concerns about whether they were undercutting federal privacy laws, the report said. Children’s Online Privacy Protection Act, or COPPArequire that children’s online services obtain parental consent before collecting personal data from users under 13 for purposes such as ad targeting.

The report’s findings raise new concerns about YouTube’s advertising of children’s content. In 2019, YouTube and Google agreed on it pay a record $170 million in fines to settle allegations by the Federal Trade Commission and the state of New York that the company had illegally collected personal information from children who watch children’s channels. Regulators said the company had profited from using children’s data to target them with ads.

YouTube then said it would limit the collection of viewer data and stop serving custom ads on children’s videos.

On Thursday, two US senators sent a letter to the FTC urging it to investigate whether Google and YouTube had violated COPPA, citing Adalytics and reporting by The New York Times. Senator Edward J. Markey, Democrat of Massachusetts, and Senator Marsha Blackburn, Republican of Tennessee, said they were concerned that the company may have tracked children and shown them targeted ads without parental consent, facilitating “the massive collection and distribution” of child data .

“This conduct by YouTube and Google is estimated to have affected hundreds of thousands, to potentially millions, of children across the United States,” the senators wrote.

Adalytics identified more than 300 brands of ads for products for adults, such as cars, on nearly 100 YouTube videos designated as “made for children” that were shown to a user who was not logged in and that linked to advertisers’ websites. It also found several YouTube ads with violent content, including explosions, sniper rifles and car crashes, on children’s channels.

An analysis by The Times this month found that when a viewer not logged in to YouTube clicked on the ads on some of the site’s children’s channels, they were taken to brand websites that placed trackers – bits of code used for purposes such as security, ad tracking or user profiling – from Amazon, Meta’s Facebook, Google, Microsoft and others – on users’ browsers.

As with children’s television, it is legal and common to show advertisements, including for adult consumer products such as cars or credit cards, on children’s videos. There is no evidence that Google and YouTube violated their 2019 agreement with the FTC

The Times shared some of Adalytic’s research with Google ahead of publication. Michael Aciman, a Google spokesman, called the report’s findings “deeply flawed and misleading.” Google has also disputed an earlier Adalytics report on the company’s advertising practices, which was first reported by The Wall Street Journal.

Google told The Times that showing ads to adults on children’s videos was useful because parents who watched could become customers. It also noted that showing violent ads on children’s videos violated company policy and that YouTube had “changed the classification” of the violent ads cited by Adalytics to prevent them from appearing on children’s content “moving forward.”

Google said it did not run personalized ads on children’s videos and that its ad practices were fully compliant with COPPA. When ads appear on children’s videos, the company said, they are based on the webpage’s content, not targeted to user profiles. Google said it did not notify advertisers or tracking services if a viewer coming from YouTube had seen a children’s video — only that the user had viewed YouTube and clicked on the ad.

The company added that it had no way to control data collection on a brand’s website after a YouTube viewer clicked on an ad. Such data collection, Google said, can happen when clicking on an ad on any website.

Even so, ad industry veterans said they had found it difficult to prevent their clients’ YouTube ads from appearing on children’s videos, according to recent Times interviews with 10 senior executives at ad agencies and related companies. And they argued that YouTube’s ad placement had put prominent consumer brands at risk of compromising children’s privacy.

“I’m incredibly concerned about it,” said Arielle Garcia, chief privacy officer for UM Worldwide, the ad agency that ran the BMO campaign.

Garcia said she was speaking generally and could not comment specifically on the BMO campaign. “It shouldn’t be that difficult to ensure that children’s data is not collected and used inappropriately,” she said.

Google said it gave brands a one-click option to exclude their ads from appearing on YouTube videos made for children.

The BMO campaign had targeted the ads using Performance Max, a specialized Google AI tool that doesn’t tell businesses which specific videos their ads were shown on. Google said the ads had not initially excluded children’s videos and that the company recently helped the campaign update its settings.

In August, an ad for another BMO credit card appeared on a video on Moolt Kids Toons Happy Bear channel, which has more than 600 million views on its cartoons. Google said the second ad campaign did not appear to have excluded children’s videos.

Jeff Roman, a spokesman for BMO, said “BMO does not aim to nor does it knowingly target minors with its online advertising and takes steps to prevent its ads from being shown to minors.”

Several industry veterans reported problems with more conventional Google ad services. They described how they had received reports of their ads appearing on children’s videos, made long lists to exclude those videos, only to later see their ads appear on other children’s videos.

“It’s a constant game of Whac-a-Mole,” said Lou Paskalis, former head of global media for Bank of America, who now runs a marketing consulting firm.

Adalytics also said Google had placed persistent cookies — the types of files that can track the ads a user clicks on and the websites they visit — on YouTube’s children’s videos.

The Times observed persistent Google cookies on children’s videos, including one advertising cookie called IDE. When a viewer clicked on an ad, the same cookie was also displayed on the ad page they landed on.

Google said it used such cookies on children’s videos only for business purposes permitted under COPPA, such as fraud detection or measuring how many times a viewer sees an ad. Google said the cookie’s content “was encrypted and not readable by third parties.”

“Under COPPA, the presence of cookies is permitted for internal operations including fraud detection,” said Paul Lekas, director of global public policy at SIIA, a software industry group whose members includes Google and BMO, “as long as cookies and other persistent identifiers are not used to contact an individual, create a profile, or engage in behavioral advertising.”

The Times found an ad for Kohl’s clothing that continued “Wheels on the bus, a nursery rhyme video that has been viewed 2.4 billion times. A viewer who clicked on the ad was taken to a Kohl’s web page that contained more than 300 tracking requests from approximately 80 third-party services. These included a cross-site tracking code from Meta that could enable it to follow viewers of children’s videos across the web.

Kohl’s did not respond to multiple requests for comment.

A Microsoft spokesperson said: “Our commitment to privacy shapes how we build all of our products and services. We are receiving more information so we can conduct further investigations as needed.” Amazon said it banned advertisers from collecting children’s data using its tools. Meta declined to comment.

Children’s privacy experts said they were concerned that the configuration of Google’s interconnected ecosystem – including the most popular browser, video platform and largest digital advertising company — had facilitated the online tracking of children by tech giants, advertisers and data brokers.

“They’ve created an assembly line that collects data from children,” said Jeff Chester, executive director of the Center for Digital Democracy, a nonprofit organization focused on digital privacy.

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