Child, Consumer Advocacy Groups Ask FTC To Investigate Google's YouTube Kids App

Google lulled parents into believing the app would keep kids from the dark corners of the Internet, said Consumer Watchdog Privacy Project Director John Simpson during a media call Tuesday. But the app is “full of content that is advertising masquerading as some sort of story or entertainment,” Simpson said. The “videos provided to children on YouTube Kids intermix commercial and other content in ways that are deceptive and unfair to children and would not be permitted to be shown on broadcast or cable television,” the letter said. “Many of the video segments endorsing toys, candy and other products that appear to be ‘user-generated’ have undisclosed relationships with product manufacturers in violation of the FTC’s guidelines concerning the use of endorsements and testimonials in advertising.”

The agency "has received the letter and will review the concerns raised by these groups,” said an FTC spokesman. Google didn't comment.

Google launched its YouTube Kids app Feb. 23, describing it as the “the first Google product built from the ground up with little ones in mind,” the letter said. Google said it had “taken out the complicated stuff and made an app even little ones can navigate -- that means big buttons, easy scrolling, and instant full-screen,” as the app was “made for ages 5 and under,” the letter said. Parental controls are offered, but the groups said “any child who can read can easily access these parental controls.”

“There is nothing 'child friendly' about an app that obliterates long-standing principles designed to protect kids from commercialism,” said Campaign for a Commercial-Free Childhood Associate Director Josh Golin. “YouTube Kids' advertising policy is incredibly deceptive.” For example, “Google claims it doesn't accept food and beverage ads but McDonald's actually has its own channel and the 'content' includes actual Happy Meal commercials,” said Golin. Brands with their own channels on the app include McDonald's, Barbie, Fisher-Price and Lego, the letter said. “Videos on these channels are mostly advertising even though they are not labeled as such.”

“In marketing the app to parents, Google claims that all ads are pre-approved by YouTube’s policy team to ensure compliance with the app’s rigorous advertising policy when, in fact, much of the content available on the app violates its own policies,” the letter said, which is why the groups want the FTC to “take action” and “stop these and any other deceptive or unfair practices uncovered as a result of its investigation.” Angela Campbell of the Institute for Public Representation at Georgetown Law, counsel to the coalition on the complaint, has asked for the FTC to "investigate whether Disney and other marketers are providing secret financial incentives for the creation of videos showing off their products,” a news release said. “The FTC’s Endorsement Guides require disclosure of any such relationships so that consumers will not be misled," Campbell said.

When a selected video segment is finished on the app, another segment from the same channel will start automatically, the letter said, but sometimes a 30- or 60-second video ad is shown between video segments. After several segments are watched, a category called “recommended” appears on the app, Simpson said. It isn't clear how the app determines which videos to recommend, Simpson said, which is why the groups have asked the FTC to investigate whether Google is tracking children’s online viewing habits. If Google is tracking children’s viewing habits, the groups asked the FTC to determine whether Google gave direct notice and “obtained verifiable parental consent before tracking” children as required by the Children's Online Privacy Protection Act.

“YouTube Kids is the most hyper-commercialized media environment for children I have ever seen,” said Dale Kunkel, University of Arizona communications professor. “Many of these advertising tactics are considered illegal on television, and it's sad to see Google trying to get away with using them in digital media,” he said. “Children deserve effective safeguards that will protect them regardless of the ‘screen’ they use,” said Center for Digital Democracy Executive Director Jeff Chester. He said new policies “will be required to address the growing arsenal of powerful digital marketing and targeting practices that are shaping contemporary children’s media culture -- on mobile phones, social media, gaming devices, and online video platforms.”

Simpson clarified that the groups aren't advocating the app be ad-free but said Google should be held to the same ad standards as broadcast entities, especially for children. An appropriate video buffer needs to make it clear that what the child just watched was an ad, Simpson said. “Simply requiring a disclosure that a video is ‘advertising’ or that there is a relationship between the endorser and the product manufacturer, however, would be insufficient to protect children from unfair and deceptive practices,” the letter said, because “most children under 6 cannot read.” “Even if disclaimers were provided orally, the cognitive limitations of children under 6 or even 8 means that they cannot understand that the purpose of advertising is to persuade and to defend against such persuasion,” the letter said.