The new YouTube for Kids app has been out for a month, which provides us with sufficient time to offer some thoughts on the new app as well as the move by Google to acknowledge COPPA compliance issues.
Google deserves two thumbs up for YouTube for Kids. The app represents the first serious acknowledgment by one of the three big Internet titans [Google, Facebook, Twitter] that children under 13 are using its online properties. Most companies hide behind age gateways to create a legal defense to such claims while ignoring the practical reality that we all know young children are members of and using sites such as Facebook, YouTube, and other large sites.
The app is interesting for a number of reasons. It provides a unique database of videos targeted at children in four categories – shows, music, learning and explore. Each video is approved by YouTube prior to being added to the database. The app then presents the viewer with a larger font and graphic interface that is simplified in comparison to the general YouTube appearance. Google also intends to create content specifically for kids in the future.
As with traditional video viewing, YouTube for Kids plays advertisements along with the videos shown. Unlike general YouTube offerings, these videos are not tailored to the online profile of the child developed through online behavioral tracking. Such tracking would involve the collection of personal identifiers and trigger COPPA compliance. To avoid this, the advertising shown in the videos is merely tailored to the subject matter of the particular video.
Google is a for-profit company and has shareholders to appease every financial quarter. As a COPPA attorney, my primary interest in the new app has always been how Google will monetize it without triggering COPPA compliance by providing advertisers with user information. Under the 2013 COPPA Rule, sites are now responsible for making sure any third party advertisers are COPPA compliant and must provide notice of such companies to parents. Complying with such requirements represents a practical nightmare, particularly for an app with so many users, video providers and advertisers such as this one.
Google’s response is brilliant. Although YouTube shows ads with videos on YouTube for Kids, the apps are not “clickable.” The advertisements are, instead, more like television ads offering passive branding. Since children cannot visit third-party sites by clicking on ads shown with videos, there is no collection of personal information by advertisers and no COPPA obligations arise.
It is a sublime solution to a difficult practical problem.
The questions is will it work long-term?
Analytics plays a huge role in measuring the effectiveness of online marketing campaigns. Consider another Google property – Adwords. A company marketing through Adwords can place code on their online property to track how many clicks convert into leads. The information is now so detailed that one can identify the cost per lead at a glance and then determine the cost of each sale using internal information. An advertiser can improve these numbers by continually tweaking their marketing and analyzing the changes to the analytical numbers.
Advertisers will receive no such information from YouTube for Kids. Since ads on the videos will not be “clickable”, no data exists to establish whether said marketing is leading to sales, email signups, or another desired outcome. At best, marketers may see a total number of views an advertisement received over a period of time. Views are wonderful in the abstract, but not particularly helpful in determining whether a marketing campaign is producing results. A million views might produce 10,000 desired actions or 10. There are no objective data markers for making the determination.
The question for advertisers is whether the lack of information is a sufficient hindrance to keep them from advertising on YouTube for Kids. It seems doubtful. Companies marketing to children under 13 are already familiar with marketing restrictions online and thus conditioned to be receptive to a lack of analytical information. Flying blind is the norm, which suggests Google should do just fine with YouTube for Kids.
All in all, YouTube for Kids is an impressive app from both a practical and COPPA perspective. It will be interesting to see how Google tackles creating child-centric versions of its other online offerings.
Richard A. Chapo, Esq.