YouTube appears to be violating a number of its own policies relating to advertising on kids’ content, according to a new report today from Adalytics, an ad quality and transparency platform. These violations could result in collection and sharing of childrens’ data, while also leading to misplaced and wasted ad spend for brands and agencies. The report, released weeks after a previous Adalytics report accused YouTube of violating its own standards for TrueView buys, places the trustworthiness of YouTube’s ad offering under fresh scrutiny.
The new report can be broken up into two central claims. The first is that Google collects data on users who watch kids’ videos (beyond that which is necessary for YouTube’s basic functioning), which the platform has previously pledged not to do. This includes serving of ads based on demographic and behavioural data, and tracking users who click on ads.
The second, related claim is that a lot of advertiser spend is ending up on made-for-kids videos even in cases where advertisers are specifically trying to avoid children’s content.
Anonymous media buyers cited in the report say these allegations are concerning. One source responded that “Google has failed advertisers, again”, adding that advertisers are “overdue real transparency and Google needs to be made accountable”. Another source said the report gels with their own experience of running ads on YouTube, where Google’s tools have fallen short when it comes to avoiding advertising next to kids content.
Sean Cunningham, president and CEO of the Video Advertising Bureau, said the new report helps cement advertisers’ demands that Google opens up access and insight into its YouTube inventory. “What is at stake is your recourse as an ad spender, a recourse that will die at Google unless they are made to pivot to real transparency – like full granular disclosure on the lifecycle of every YouTube ad and ad impression, for starters.”
What does the report say?
The report (which can be read in full here) is based on publicly available tools and documentation, as well as data provided by media buyers. Adalytics says it began investigating the issue when working on its TrueView report, as it noticed that large portions of brands’ TrueView campaigns were being served on channels which appeared to be directed towards children. Some of those brands, when asked by Adalytics, said they specifically tried to avoid running ads next to kids content.
After further investigation, Adalytics found that keyword exclusion lists for terms like “kids” and “children” don’t seem effective at preventing ads from appearing on kids content, even when the videos or channels in questions specifically include these words in their titles.
The company also found that multiple YouTube products are serving ads on kids videos in a somewhat questionable manner. Google’s Performance Max offering for example appeared to place adult brands’ ads on “made for kids” YouTube channels – but due to PMax’s black box nature, it’s not possible to tell when this is happening. YouTube’s premium ad offering YouTube Select meanwhile was seen serving ads on relatively low subscriber count “made for kids” YouTube videos.
But YouTube’s unreliability in identifying or recognising kids videos and channels also raises potential data safety concerns.
YouTube says that it doesn’t run personalised ads on kids content, and limits data collection only to that which is necessary for the basic functioning of the platform. But Adalytics says it saw cases where YouTube set long-lasting cookies specifically for the purposes of ad targeting and tracking on the browsers of consumers watching YouTube videos that were clearly labelled as “for kids”. The platform also appears to be running personalised ads on YouTube videos which are labelled as made-for-kids. And in some cases, it appears to be setting and sharing tracking IDs when viewers of “made-for-kids” videos click on an ad.
Assuming this is the case, this suggests that YouTube isn’t adhering to its own policies around protection of children’s data. But it also places advertisers at risk, as they could unknowingly be receiving data relating to children. And Adalytics said that some companies “appear to be scraping or exfiltrating Google generated user identifiers from viewers of “made for kids” videos who had clicked an ad”.
Are YouTube’s tools fit for purpose?
It’s important to clarify a few points around this report. Firstly, as Adalytics begins by saying, it doesn’t make any claims that laws have been violated. Secondly, it’s talking about data and ads relating to made-for-kids content, rather than childrens’ data, or ads shown to kids – the difference being that in some cases at least, adults could have been watching made-for-kids videos. (It’s worth noting here however that YouTube’s own policy is to “treat data from anyone watching children’s content on YouTube as coming from a child, regardless of the age of the user”.
The report also doesn’t make claims of malicious intent from YouTube. Adalytics doesn’t state that Google is intentionally ignoring advertisers’ efforts to avoid kids content, or knowingly setting cookies and running personalised ads on kids content. In fact the investigation found cases where Google’s own products, including its NFL Sunday Ticket, were advertised on kids content, even though these products aren’t available to under 18s (meaning Google itself would be motivated to avoid having these ads run alongside kids content).
But it does raise questions about the ability of YouTube’s tools to identify and appropriately respond to made-for-kids content.
YouTube uses a mix of self-reporting and machine learning to identify kids videos and channels. But Adalytics identified channels which weren’t labelled as made-for-kids, even though they explicitly reference children in their titles. Channels including DRAWINGS FOR KIDS, Car Videos for kids, and Musical Playtime for Kids | Nursery Rhymes all appear to fly under YouTube’s radar.
And even when YouTube has correctly identified made-for-kids content, it still seems to not be applying the appropriate safeguards. This will be a particular concern relating to data privacy, as companies can receive heavy fines for mishandling of children’s data.
It also reignites debate around the lack of transparency into some of YouTube’s products. Some of these issues would be easier to detect and avoid if advertisers knew what they were buying. But products like PMax don’t give advertisers data on where their ads are appearing, making it difficult or impossible to pick up on these sorts of faults.
Ruben Schreurs, chief strategy officer of advertising auditing firm Ebiquity, summarised the issues as follows: “Advertisers rely on the efficacy of the tools and systems operated by Google to help them prevent inadvertent misuse of data and/or targeting of children in their advertising campaigns on YouTube; in many categories even bound by regulations with severe penalties and reputational risk in case of non-compliance, such as for advertisers of products in the alcoholic beverages or sugary product categories. The alleged shortcoming of YouTube in this regard as outlined in the Adalytics study, if true, is concerning. We look forward to Google’s response on the matter and hope any technical issues will swiftly be resolved to ensure children are appropriately protected when engaging with content on YouTube.”
