program areas Digital Youth

Washington, DC – Tuesday, May 19 – Two leading child and consumer advocacy groups have filed an important update to their Federal Trade Commission complaint against Google’s YouTube Kids app for false and deceptive marketing. In a letter sent to the Commission today, the groups charged that Google is deceiving parents by marketing YouTube Kids as a safe place for children under five to explore when, in reality, the app is rife with videos that would not meet anyone’s definition of “family friendly.” A review by the Campaign for a Commercial-Free Childhood (CCFC) and Center for Digital Democracy (CDD) has found a significant amount of content that would be extremely disturbing and/or potentially harmful for young children to view, including: Explicit sexual language presented amidst cartoon animation Videos that model unsafe behaviors such as playing with lit matches, shooting a nail gun, juggling knives, tasting battery acid, and making a noose A profanity-laced parody of the film Casino featuring Bert and Ernie from Sesame Street Graphic adult discussions about family violence, pornography, and child suicide Jokes about pedophilia and drug use Advertising for alcohol products CDD and CCFC provided a video (link is external) to the FTC today documenting an array of inappropriate content that can found on YouTube Kids. “Federal law prevents companies from making deceptive claims that mislead consumers," said Aaron Mackey, the coalition’s attorney at Georgetown Law's Institute for Public Representation. "Google promised parents that YouTube Kids would deliver appropriate content for children, but it has failed to fulfill its promise. Parents rightfully feel deceived by YouTube Kids." Google claims that YouTube Kids was “built from the ground up with little ones in mind” and is “packed full of age-appropriate videos.” The app includes a search function that is voice-enabled for easy use for preschool children. Google says it uses “a mix of automated analysis, manual sampling, and input from our users to categorize and screen out videos and topics that may make parents nervous.” Google also assures parents that they “can rest a little easier knowing that videos in the YouTube Kids app are narrowed down to content appropriate for kids.” But, as the complaint explains: Google does not, in fact, “screen out the videos that make parents nervous” and its representations of YouTube Kids as a safe, child-friendly version of YouTube are deceptive. Parents who download the app are likely to expose their children to the very content they believed they would avoid by using the preschool version of YouTube. In addition to the unfair and deceptive marketing practices we identified in our initial request for an investigation, it is clear that Google is deceiving parents about the effectiveness of their screening processes and the content on YouTube Kids. “In the rush to expand its advertising empire to preschoolers, Google has made promises about the content on YouTube Kids that it is incapable of keeping,” said Josh Golin, Associate Director of CCFC. “As a parent, I was shocked to discover that an app that Google claims is safe for young children to explore includes so much inappropriate content from the Wild West of YouTube.” Today’s letter is an update to the advocates’ April 7, 2015 FTC complaint that charged Google with engaging in unfair and deceptive practices towards children and their parents. That complaint detailed how YouTube Kids featured ads and other marketing material that took advantage of children’s developmental vulnerabilities. It also noted that the “blending of children’s programming content with advertising material on television has long been prohibited because it is unfair and deceptive to children. The fact that children are viewing the videos on a tablet or smart phone screen instead of on a television screen does not make it any less unfair and deceptive.” The complaint also called on the FTC to address the failure by Google to disclose that many makers of so-called “user-generated” videos featuring toys and candy have relationships with those product's manufacturers. “The same lack of responsibility Google displayed with advertising violations on YouTube Kids is also apparent in the content made available on the app,” observed Dale Kunkel, Professor of Communication at University of Arizona. “There is a serious risk of harm for children who might see these videos. It’s clear Google simply isn’t ready to provide genuinely appropriate media products for children.” Added Jeff Chester, executive director of CDD, “Google gets an 'F' when it comes to protecting America’s youngest kids. The failure of the most powerful and technologically advanced media company to create a safe place for America’s youngest kids requires immediate action by the FTC.” Today’s letter to the FTC is available below. The coalition’s original FTC complaint is available at http://bit.ly/1LeQHCN. The compilation of YouTube Kids video clips can be viewed at https://vimeo.com/127837914 (link is external).

Washington, DC – Tuesday, April 7 – A coalition of prominent children’s and consumer advocacy groups filed a complaint with the Federal Trade Commission (FTC) today requesting an investigation of Google, charging the company with unfair and deceptive practices in connection with its new YouTube Kids app. The complaint (link is external) details a number of the app’s features that take advantage of children’s developmental vulnerabilities and violate long-standing media and advertising safeguards that protect children viewing television. Among the specific practices identified in the complaint are: Intermixing advertising and programming in ways that deceive young children, who, unlike adults, lack the cognitive ability to distinguish between the two; Featuring numerous “branded channels” for McDonald’s, Barbie, Fisher-Price, and other companies, which are little more than program-length commercials; Distributing so-called “user-generated” segments that feature toys, candy, and other products without disclosing the business relationships that many of the producers of these videos have with the manufacturers of the products, a likely violation of the FTC’s Endorsement Guidelines. When it launched the YouTube Kids app in February, Google described it as “the first Google product built from the ground up with little ones in mind.” As the complaint points out, however, the company appears to have ignored not only the scientific research on children’s developmental limitations, but also the well-established system of advertising safeguards that has been in place on both broadcast and cable television for decades. Those important policies include (1) a prohibition against the host of a children’s program from delivering commercial messages; (2) strict time limits on the amount of advertising any children’s program can include; (3) the prohibition of program-length commercials; and (4) the banning of “product placements” or “embedded advertisements.” Such “blending of children’s programming content with advertising material on television,” the group’s complaint declares, “has long been prohibited because it is unfair and deceptive to children. The fact that children are viewing the videos on a tablet or smart phone screen instead of on a television screen does not make it any less unfair and deceptive.” The complaint also charges that Google is violating its own advertising policies for YouTube Kids. For example, while the company promises that food and beverage ads will not appear on the app, advertising and promotions for junk food are prominently featured throughout. “YouTube Kids is the most hyper-commercialized media environment for children I have ever seen,” commented Dale Kunkel, Professor of Communication, University of Arizona. “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.” “There is nothing 'child friendly' about an app that obliterates long-standing principles designed to protect kids from commercialism,” added Josh Golin, Associate Director of Campaign for a Commercial-Free Childhood. “YouTube Kids exploits children’s developmental vulnerabilities by delivering a steady stream of advertising that masquerades as programming. Furthermore, YouTube Kids' advertising policy is incredibly deceptive. To cite just one 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.” Angela J. Campbell of the Institute for Public Representation at Georgetown Law, who serves as counsel to the coalition, called on the FTC to "investigate whether Disney and other marketers are providing secret financial incentives for the creation of videos showing off their products. The FTC’s Endorsement Guides require disclosure of any such relationships so that consumers will not be misled." “In today’s digital era, children deserve effective safeguards that will protect them regardless of the ‘screen’ they use,” explained Jeff Chester, Executive Director of the Center for Digital Democracy. “In addition to ensuring that Google stops its illegal and irresponsible behavior to children on YouTube Kids, 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.” Organizations signing the complaint include: the Center for Digital Democracy, Campaign for a Commercial-Free Childhood, American Academy of Child and Adolescent Psychiatry, Center for Science in the Public Interest, Children Now, Consumer Federation of America, Consumer Watchdog, Consumers Union, Corporate Accountability International, and Public Citizen

By Jeff Chester (link is external) / AlterNet (link is external) April 6, 2015 There is a “digital gold rush” underway to cash in on young people’s passion for interactive media. Google and other media (link is external) and ad companies are working to transform kids’ clicks and views into bundles of cash and burgeoning brand loyalty. While TV still dominates a great deal of kids’ media viewing, they are also consuming content (often simultaneously) on mobile devices, tablets, and through streaming or video-on-demand services. In February, Google (link is external) launched its YouTube Kids app for children five and under; Disney acquired leading youth-focused online video producer Maker Studios (link is external) last year in a more than $500 million deal, giving it control of “the largest content network on YouTube”; Viacom’s Cartoon Network (CN) now offers CN’s “Anything,” providing mobile phone-friendly “micro” content and promising to serve a “network of devices giving a network of experiences to a network of fans”; and Amazon, Netflix, and others are sending more “kid targeted” streaming video-on-demand programming. But unlike broadcast and cable TV, where there is at least a handful of FCC regulations that prevent some of the worst practices perfected by advertisers for targeting kids, the online world is mostly a regulatory-free zone when it comes to digital marketing. Advocates and child-health experts fought a long campaign, from the 1970’s to the 1990’s, to ensure that TV didn’t take unfair advantage of how kids relate to advertising—so that shows weren’t simply “program-length commercials” for toys, or that the “host” or star of a program—such as a cartoon character—didn’t also pitch products at the same time. There were also modest limits in how many ads could appear in so-called “kidvid” programming. These rules reflected research on children’s development and their inability to fully comprehend the nature of advertising. The FCC (link is external) policies embraced an important principle: children were to be treated differently than adults when it came to TV advertising. Such safeguards are even more important in the digital era, when sophisticated advertising techniques gather and analyze data on everything an individual does, and incorporate an array of powerful interactive features on mobile devices and PCs that have been designed to get results. Parents and others who care about children should be forewarned: For Google, Facebook, media companies like Nickelodeon, toy companies, and junk food marketers, the Internet is a medium whose primary focus is to help brand advertisers turn young people into fans, “influencers” (to spread the word via social media), and buyers of products. Although children benefit from using educational apps, and have greater access to more diverse entertainment and other content, the motivation really at work is to mold this generation of youth into super-consumers, encouraged to engage in a never-ending buying cycle of goods and services. Children (link is external) are now a key target for Google’s “monetization” strategies, helping the company cash in from the sales of toys, apps, junk food, and other products. (So-called “tweens” in the U.S. alone are said to influence (link is external) some $200 billion a year in spending, including $43 billion of their own money.) With Google’s overall revenue growth slowing, with Facebook aggressively seeking to displace it as the global digital advertising leader, and with consumers flocking to mobile phones (instead of PCs) to view videos and use apps, kids—which were one of the only consumer groups not formally targeted by Google until now—are viewed as an essential new market to conquer. In February, Google unveiled a new advertiser-supported “YouTube Kids” app, its first “product built from the ground up with little ones in mind.” Google’s YouTube Kids “product manager” claimed that “the app makes it safer and easier for children to find videos on topics they want to explore.” Google also promised that ads “that aren’t kid-appropriate don’t surface.” But Google’s YouTube Kids (link is external) is filled with ads disguised as programming and product pitches that violate rules that broadcast and cable TV channels have to follow. A coalition of consumer, privacy, and children’s advocacy groups urged the FTC to investigate Google’s new YouTube Kids app, as well as how the company targets older children on YouTube itself. (Six (link is external) of YouTube’s leading channels are “aimed at children.”) Google wants to place even the youngest kids inside its powerful marketing apparatus, making sure they will help the company generate much-needed profits as they grew older. It is encouraging brands to take advantage of how young people are engaging in a “multi-screen experience,” including watching video on smart phones, and how YouTube combines the attributes of video service and social networking. Google explains (link is external) that YouTube takes the most powerful medium for connecting with the heart and mind—video—and elevates it from a one-way communication to a two-way experience by inviting brands and consumers alike to connect, curate, create and form community … . On YouTube, brands have the unparalleled opportunity to connect with their most valuable audience and the creative freedom to do so in the most compelling way. The reward for the marketer is a fanbase moved not only emotionally, but also literally, to purchase, comment, share and advocate for that brand. In short, YouTube moves people to choose your brand. As an article on the launch of YouTube Kids explained, “If YouTube can earn the trust of parents and hook (link is external) a new group at an even earlier age, then that’s tapping a whole new market of users that will literally grow up with the service—and use it for a much longer portion of their lives.” While appearing as a distribution service for many programmers, independent and professional, YouTube is a key part of an incredibly sophisticated, elaborate, and highly powerful global marketing apparatus. Google executives recently pledged that they are “listening to brands” and taking “action” to help make YouTube a more effective platform to help accomplish their goals. YouTube: “one of the biggest Big Data projects in the world” YouTube incorporates (link is external) all of Google’s expertise in gathering and analyzing consumer information, so a user, even a young one, can be effectively targeted with marketing. YouTube, it explains, “is one of the biggest Big Data projects in the world.” “At YouTube, data drives the way we make decisions,” including to help its advertisers “get closer to the holy grail of precision targeting.” YouTube, explains the company, has “one of the world’s richest datasets,” which it combines with “Google’s cutting-edge technology” to “transform insights into real-world products.” YouTube continually researches and develops ways to measure and analyze how ads can work more effectively; it identifies “new algorithms and methods for optimizing ads,” “researches new ways for modeling end user behavior,” and more. Its data fuel YouTube’s “recommendation systems,” and the company is now “pushing the boundaries of science and engineering” to make its home page deliver more revenue. It offers its users, including children, “recommended videos” as well as other products that help its advertisers. Through machine learning about us, including analyzing our data, Google plans to further strengthen how it can “introduce users to areas of their interest that many did not realize YouTube had.” YouTube is now working to “build the next generation game-console based TV experience with YouTube video content,” which will deliver “a compelling lean back experience with monetization and e-commerce offerings” (including “pay-per stream” and ad content), as well as through partnerships that “integrate” its content. Generating revenues by attracting and targeting gamers is a key part of YouTube’s marketing-to-youth strategy. It is also positioning YouTube to be a key part of digitally connected “Living Room” devices, including “game consoles, smart TV’s, set-top boxes” to “drive distribution and user engagement.” We “put your brand in their hand” Through its “brand channels”—“a 24/7 broadcast center where customers can watch, share and love your brand”—YouTube helps advertisers like Red Bull and Walmart “energize” its customers. These channels can be specially configured to work well with mobile devices, explains Google, so marketers (link is external) can “put your brand in their hand.” Google also offers a “Custom Brand Channel” on YouTube, “the highest level of brand channel customization,” which incorporates special “interactive applications” designed to promote the “branding” experience more effectively. Last year, as part of its ongoing effort to work more closely with leading advertisers, Google also unveiled its “Partner Select” program, which helps its clients take advantage of its advanced data-targeting platform to run ads on its top-ranked video programming. Google is working to have YouTube play a key role erasing what’s left of the boundaries that have separated advertising and content. Through what it calls “content marketing,” YouTube promises to help its advertisers take advantage of our “shortening attention spans” to positively respond to a brand’s message, explaining that “In a world of shortening attention spans and increasing options, advertising is undergoing a sea change. More and more, ads are becoming content that people choose to watch. … [W]e use the tools and know-how developed by a generation of YouTube content creators to help brands develop ads that will resonate with today’s consumers.” As a leader in using mobile phones to target individuals based on their actual location, Google is also in the forefront of delivering its content on smart phones and similar devices, boasting that “viewing video on smartphones is far less distracted than it is on TV.” YouTube: “Precision Targeting at Scale” To help its advertisers, YouTube provides “precision targeting at scale” thatleverages (link is external) “the sight, sound and motion of video, the most persuasive ad format every evented.” Google claims that its “targeting tools are so precise” marketers “can show your ad to folks around your corner or to anyone around the world.” One can target by age, gender, zip code, language, interest, and can “retarget” someone whose data have been (largely secretly) collected when they were on YouTube or other sites. Google offers advertisers a formidable arsenal of “3rd Party Audience Data” that can incorporate details on one’s finances, buying behavior, and many other personal details. Now reaching one billion people worldwide, YouTube identifies Hispanics, teens, those “hard to reach,” as well as adult men and women as key targets; it notes, for example, that “54% of all teens” and “59% of all Hispanics” use it. (Among the “facts” on Hispanics it lists for advertisers is that “76% currently own a pet” and “58% are grocery decision makers in their household.”) YouTube also plays a direct role helping key advertisers achieve their goals, including through its “in-house creative team” (which it calls “The ZOO”) that “can unleash the true power of your message with a custom campaign.” YouTube’s “Brand Nirvana” Promotes Junk Food to Kids Google has been helping Mondelez, Pepsi, and other fast-food marketers push their products—despite concerns about the global obesity epidemic—especially on young people. Last year, Mondelez signed a deal with Google that featured the candy (link is external) and snack company (Oreo, etc.) making a commitment to “accelerate” its investment in online video. The pact involved the use of Google’s advanced data-driven targeting system (known as “programmatic buying”) and the development of more “branded content.” Google and Mondelez are “partnering on content pilots through YouTube’s Brand Partner Program … [to produce] low-cost video content featuring influential digital stars with Sour Patch Kids in the U.S.” Mondelez’s YouTube channel for Oreos features an array of ads dressed up as games, in English and Spanish, which is typical of Google’s use of video to promote junk food products using the full power of its platform. Fast-food companies, including such brands as Coca-Cola, Mars, Mondelez, Wendy’s, and Post cereal, are also using advanced analytics on YouTube viewing to help refine their targeting strategies. Frank Cooper, Pepsi’s chief marketing officer, was a keynote speaker at YouTube’s “Brandcast” 2014 event. In announcing that Pepsi has increased its spending for YouTube services by 50 percent over the last year, Cooper noted that “we live in a world where visual content in the digital space is the new center of gravity for pop culture,” and being on YouTube and related digital applications enables Pepsi (link is external) to be part of a conversation that is “driving culture.” When people share “your content with their friends,” he noted, it is “brand nirvana.” YouTube as Toy Promotion Central Google is positioning YouTube (link is external) to be a central place for children to learn about toys they want their parents or family to buy. As one toy business analyst explained, “It’s a totally new way of advertising. [The YouTube channels] are becoming more and more important.” Although Google’s terms of service (ToS (link is external)) for YouTube requires users to be 13 and older, it’s clear that it is targeting kids—and violating its own policy—in order to profit from the children’s market. Its ToS states that “the Service is not intended for children under 13. If you are under 13 years of age, then please do not use the Service. There are lots of other great web sites for you. Talk to your parents about what sites are appropriate for you.” Yet despite its own ToS banning children from signing up, YouTube is clearly targeting kids. For example, “FunToyzCollector (link is external),” which describes itself as “all about kid-friendly videos for toddlers, babies, infants and pre-school children,” recently placed first in views among all the YouTube channels (517.3 million). The channel engages in “unboxing” toys, an increasingly sought after YouTube genre that provides viewers with a “virtual tour” of kids products, such as “Sofia the First Balloon Tea Party 2-in-1 Playset with Disney Frozen Princess Anna Elsa of Arendelle.” Very popular with young kids in the U.S., the YouTube ad-supported channel made its owner an estimated $4.9 million last year. Kids either find or are shown these channels as they search for new toys to buy or to receive as presents. “DisneyCarToys (link is external),” “a fun kid friendly toy channel” produced by Disney subsidiary Maker Studios, is another example of how Google profits by permitting the targeting of children. The channel is one of five toy-related YouTube channels that Disney acquired (link is external) in 2014, including “HobbyKidsTV, ToyReviewToys, AllToyCollector, and TheEngineeringFamily.” These popular “top 40 toy channels worldwide,” which integrate Disney’s characters and brands into the programming content, are now part of Disney’s “merchandising” strategy, which will include more brand tie-ins and advertising. Maker Studios itself has a major kids marketing presence on YouTube. It describes its “Cartoontium (link is external)” set of programs as “the place to find all the best kid’s entertainment on YouTube!” One of its channels is called “Messy Painting in the Dark-Neon Arcade,” where “Toys, games and financial support [is] provided by Hasbro.” Other Cartoonium programming features “classic episodes of Care Bears and Strawberry Shortcake.” “Strawberry Shortcake” and other programming include ads for toys (and some of these shows are also on the YouTube Kids app). One reason Disney acquired Maker, explained CEO Bob Iger, was to reap its “great access to data and algorithms,” which are gathered from billions of views collected through its 55,000 YouTube channels. Another kids’ toy–focused YouTube service is also partnering with the Disney/Maker empire. “EvanTubeHD (link is external),” involving two young children (eight and five years old) and their father, “boasts more than a billion views across” three channels. The two children “review and play with the most popular kids toys currently on shelves.” As an analyst explained why toy companies are enthusiastically seeking out relationships with kid reviewers online, “Kids trust other kids more so than they would an adult.” Maker has a broad range of marketing services it offers brands (link is external) and advertisers, including “custom pre-roll” ads (the short spots that run before a YouTube or other video content starts); channel targeting (“integrate your brand message natively into our top performing channels”); and sponsorships (“More than just a logo, our unique custom sponsorships allow you to connect with our forward leaning and deeply engaged audiences”). Maker touts its strong alliance of partners, including its “custom solutions to the world's best brands” and “effective and hyper-targeted media solutions.” Partners include Mattel, Pepsi, Warner Bros, and parent Disney. It also works with the leading ad agencies that represent major global brands “to create unique programs across our programming and talent.” In another example of how Google fails to protect children, it allows Disney to encourage its young viewers to connect to them using Facebook, Twitter and Instagram—despite these sites requiring users to be 13 years or older. So eager is Google to reap profits, it appears purposely to ignore how toy companies are establishing nothing more than 24/7 virtual ad channels on YouTube. For example, Spin Master, a “top-five” toy company, has created a “kid centric YouTube channel dubbed SpindoTV (link is external), aimed at children 6-11. Its shows are based on its toy line-up, including “Sick Bricks” and “Beat the Parents” board game. Many of its shows are a part of Google’s new YouTube Kids app. According to a Spin Master executive, “We know from our research that these kids are already on YouTube in massive numbers.” YouTube, of course, is just one method Google uses to help it reach and monetize young people. It is also “building successful apps and games” for its “Google Play for Education and Kids vertical,” helping developers create “commercially viable offerings to educators and students, parents and kids.” The popularity of YouTube among children has triggered a “must-have-the-video-network” buying strategy from companies targeting the youth market worldwide. Marketers researching youth know that kids are using YouTube as a search engine because it includes pictures, videos, and other audio-visual material. It’s also “easy to navigate” for children, with reports that “kids who are into watching TV episodes on YouTube” like to see other episodes and “recommended videos” on the sidebar. More critically, digital market researchers studying children have identified YouTube as providing an important social and creative outlet for tweens, and finding cool YouTube videos to share with others is a form of social capital. … [T]weens most frequently share cool videos when hanging out (in person) with their friends and family. … [W]e call this phenomenon clustersharing. … [I]t speaks more to their desire to physically experience videos with others—to see, to feel and to share that experience, including their thoughts and emotions. The same researchers advise marketers to take advantage of the “clustersharing (link is external)” concept, and encourage ways to “enhance that in-person, social experience. Using ad content (like a group game) or finding a way to alleviate the agonizing “live” wait of a 15-second pre-roll between each video presents “an opportunity to enrich your brand experience with this very engaged audience.” Tracking our “Consumer Journey” Google is in the forefront of digital marketing companies promising to help its clients influence and “measure” what it calls the “customer journey.” It views itself as helping them analyze and place each consumer on a continuous “path-to-purchase (link is external)” cycle, tracking us wherever we go, and using its resources to have us shop “until we drop”—online and off. Among the benefits Google promises its advertisers, for example, is that they will be able to identify and “value” their “best customers,” and “distinguish the whales from the wasted energy.” (“Whales” is a marketing industry term describing a big spender; “waste” is an ad term for a consumer deemed not valuable.) YouTube conducts research (link is external) to document how its advertisers positively impact our “recall” of various brand commercial messages. Google’s DoubleClick division, which uses data to determine the impact of video ads, offers advertisers the latest ways they can “verify” whether a person actually views a video ad on YouTube. To help its largest advertising clients measure how we respond to Google’s interactive marketing services, the company is now working with Nielsen and comScore, two of the leading global companies that assess consumer interaction with ads, including on YouTube. There are other companies also helping marketers analyze YouTube data. For example, Outrigger’s “OpenSlate (link is external)” platform “ingests, analyses and scores more than 220,000 YouTube channels on measures of engagement, consistency, influence, momentum and ad effectiveness.” (It now is up to 250,000 channels.) It “supplements YouTube data on more than 70 million videos with data from social media and proprietary demographic data. Our platform consistently incorporates brand advertising performance data to further develop video and channel level profiles.” Through its information, brand advertisers can identify “the highest-quality inventory on YouTube,” and then target them using a variety of Big Data tactics. (“Inventory,” as used by the online marketing industry, can either refer to individual users or programming content. Kids and teens are seen as highly valuable “inventory.”) Time for Regulatory Action Against Google to Protect Kids Google, as the dominant digital marketing company, has raised numerous concerns about its corporate practices, including from privacy regulators, civil liberties advocates, and competition regulators from around the world. (The company has led an anti-privacy-regulation agenda in both the U.S. and EU, to ensure that the flow of personal data that makes its interactive marketing system run will never end.) Its latest move to better monetize children through YouTube Kids is the first of what will be a succession of profit-generating ventures that help transform kids’ lives into a never-ending commercial. Even Facebook, which expressed interest in targeting children 13 and younger, has not yet directly entered the kids market. Google’s brazen move to cash in on our kids will likely spur Facebook to jettison any reticence to include them on its social network. After all, why should Google gain all the profits from this new, lucrative, and influential audience? Beyond federal and state investigations into Google’s brazen targeting of children on YouTube, what’s needed now are new policies that ensure young people aren’t unfairly treated by digital marketers. This includes rules that don’t leave children and teens vulnerable to digital marketing practices and also better protect their privacy. For example, Google is at the forefront of companies using what is called “immersive” media, to make sure brands—including on YouTube—can “grab” our attention. All of the data gathered from our use of mobile phones, social media, and online video feed so-called “profiles” that are used to target us for advertising—increasingly regardless of location (think of a mobile discount coupon from a nearby fast food outlet appearing on children’s phones as they come out of school) and in real-time (right as you are in the store cereal or toy aisle). These practices are highly questionable when targeting adults, let alone young people. Companies like Google should develop their own policies that actually protect and empower young people—not just turn them into the latest profit center. A global leader like Google, with immense profits, should only be offering kids commercial- (and data targeting-) free content. It shouldn’t be helping junk food and toy companies take advantage of kids to sell them products that don’t promote their development and health. It is doubtful, however, that Google will change course. It is, after all, primarily an advertising company whose allegiance is to the biggest brands and the marketing industry. It’s time for activist shareholders of Google and other companies to press for the adoption of new corporate policies that protect young people in the digital age. Parents will have to decide whether Google’s corporate culture, focused as it is on promoting marketing to young kids, is incompatible with their values and goals. But it will also take a movement of parents, educators, public interest groups, and policymakers to force Google and other kids marketers to act responsibly. If we want to see the next generation grow up without being greatly influenced by the most powerful advertising apparatus yet developed, this is a fight we must join.

Washington, DC – Tuesday, April 7 – A coalition of prominent children’s and consumer advocacy groups filed a complaint with the Federal Trade Commission (FTC) today requesting an investigation of Google, charging the company with unfair and deceptive practices in connection with its new YouTube Kids app. The complaint (link is external) details a number of the app’s features that take advantage of children’s developmental vulnerabilities and violate long-standing media and advertising safeguards that protect children viewing television. Among the specific practices identified in the complaint are:Intermixing advertising and programming in ways that deceive young children, who, unlike adults, lack the cognitive ability to distinguish between the two;Featuring numerous “branded channels” for McDonald’s, Barbie, Fisher-Price, and other companies, which are little more than program-length commercials;Distributing so-called “user-generated” segments that feature toys, candy, and other products without disclosing the business relationships that many of the producers of these videos have with the manufacturers of the products, a likely violation of the FTC’s Endorsement Guidelines.When it launched the YouTube Kids app in February, Google described it as “the first Google product built from the ground up with little ones in mind.” As the complaint points out, however, the company appears to have ignored not only the scientific research on children’s developmental limitations, but also the well-established system of advertising safeguards that has been in place on both broadcast and cable television for decades. Those important policies include (1) a prohibition against the host of a children’s program from delivering commercial messages; (2) strict time limits on the amount of advertising any children’s program can include; (3) the prohibition of program-length commercials; and (4) the banning of “product placements” or “embedded advertisements.” Such “blending of children’s programming content with advertising material on television,” the group’s complaint declares, “has long been prohibited because it is unfair and deceptive to children. The fact that children are viewing the videos on a tablet or smart phone screen instead of on a television screen does not make it any less unfair and deceptive.” The complaint also charges that Google is violating its own advertising policies for YouTube Kids. For example, while the company promises that food and beverage ads will not appear on the app, advertising and promotions for junk food are prominently featured throughout. “YouTube Kids is the most hyper-commercialized media environment for children I have ever seen,” commented Dale Kunkel, Professor of Communication, University of Arizona. “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.” “There is nothing 'child friendly' about an app that obliterates long-standing principles designed to protect kids from commercialism,” added Josh Golin, Associate Director of Campaign for a Commercial-Free Childhood. “YouTube Kids exploits children’s developmental vulnerabilities by delivering a steady stream of advertising that masquerades as programming. Furthermore, YouTube Kids' advertising policy is incredibly deceptive. To cite just one 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.” Angela J. Campbell of the Institute for Public Representation at Georgetown Law, who serves as counsel to the coalition, called on the FTC to "investigate whether Disney and other marketers are providing secret financial incentives for the creation of videos showing off their products. The FTC’s Endorsement Guides require disclosure of any such relationships so that consumers will not be misled." “In today’s digital era, children deserve effective safeguards that will protect them regardless of the ‘screen’ they use,” explained Jeff Chester, Executive Director of the Center for Digital Democracy. “In addition to ensuring that Google stops its illegal and irresponsible behavior to children on YouTube Kids, 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.” Organizations signing the complaint include: the Center for Digital Democracy, Campaign for a Commercial-Free Childhood, American Academy of Child and Adolescent Psychiatry, Center for Science in the Public Interest, Children Now, Consumer Federation of America, Consumer Watchdog, Consumers Union, Corporate Accountability International, and Public Citizen

Youth of color are a key focus for digital marketers, especially for fast-foods and beverages linked to the youth obesity epidemic.  The digital targeting of African American and Hispanic youth is growing, and uses a full array of sophisticated mobile, geo-location, social media and other cutting-edge marketing strategies.  Food and beverage marketers should adopt practices that stop unfair and irresponsible digital marketing practices.  The FTC and State AG's should call for safeguards.Here's the latest CDD Infographic that addresses African American youth.

In our research we've noticed that some groups get more attention than others when it comes to digital marketing. See our infographic below highlighting some of our concerns about "Junk Food Marketing to Hispanic Youth"Release Date: May 16, 2014