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Advocates Say Changes to YouTube Kids Are Woefully Inadequate
Yesterday, Google announced changes to its YouTube Kids app. These changes were ostensibly in response to a Federal Trade Commission complaint filed by the Center for Digital Democracy (CDD) and Campaign for a Commercial-Free Childhood (CCFC).
Below is a statement by CCFC’s and CDD’s attorney, Professor Angela Campbell of Georgetown University’s Institute for Public Representation, in response to Google’s changes.
Google's recent changes to YouTube Kids (YTK) have in no way addressed CDD's and CCFC's concerns about excessive and deceptive commercial content available on YouTube Kids. Google not only did not consult with CCFC and CDD, but refused their request to meet.
Rather that responding to our concerns, Google's changes to YTK are designed to allow Google to escape responsibility for allowing advertisers to use deceptive and unfair practices in marketing to the youngest children.
When Google launched YTK in February 2015, it promised parents that YTK would only show “ads that are classified as family friendly,” and that “all ads undergo a rigorous review process for compliance with our policies.” Now this language is gone and the app store description has a new, vaguely worded disclaimer at the end: "YouTube Kids contains paid ads in order to offer the app for free. Your child may also see videos with commercial content from YouTube creators that are not Paid Ads. For more information, please check out our Parental Guide."
Should a parent find the The Parental Guide (it is under the heading "Developer Website"), the parent would learn that YTK's advertising policies, which prohibit the advertising of food and beverages and other products, now apply only to so-called "paid ads" sold by Google. These "paid ads" are the 30 or 60 second videos sometimes shown before the selected video, and are labeled "ad" even if many actually appear to be public service announcements. The "paid ads" make up only a tiny fraction of the content available on YTK.
This means that the vast majority of the content available on YTK is not subject to any limits on advertising. YTK's content comes from YouTube, and as CCFC and CDD showed in their complaint to the FTC, includes actual television commercials, company-produced promotional videos, and videos with host-selling and paid product placements.
Google is intentionally allowing advertisers to reach children aged 5 and under using the YTK app. Advertising to young children, who do not have the cognitive ability to distinguish between programming and advertising, is deceptive and unfair to children. FCC regulations do not permit advertising on children's programs shown on broadcast, cable or satellite television unless it complies with certain safeguards. (For example, no host selling is permitted). Google should not be allowed to avoid such safeguards simply because the programming is distributed by an app instead of by a broadcast station or cable or satellite provider. The fact that YTK can now be viewed on full size screens as well as tablets and smart phones further illustrates the how Google is taking unfair advantage of young children.
CCFC and CDD's original complaint to the FTC can be found here: http://www.commercialfreechildhood.org/youtubekids