Last night I was browsing Youtube and a video about the entire COPPA debacle was recommended to me. I had heard something about COPPA last week and Youtube's changes, but never really looked into it as it seemed like another change blown out of proportion (which it kind of is). I watched the video and didn't really learn much more so I watched another video, and another, and another... and all of the video's had the same information and I became none the wiser, so I started doing my own investigation into COPPA and Youtube's changes. 

I went to certain news outlets who had covered it like the Verge, but again, felt like no one really did their research and everyone only had superficial information taken from two different sources, if not only just the one source.

So, I delved even deeper, and properly started to do my own research and I came across some information I found that I had to share.

Before we start, I am not an American citizen so all these rules and regulations are new to me. And also, if you think that websites like Youtube and Facebook don't let you sign up when you are under the age of 13 because "they care about the children": think again.

I started on FTC's own website: Complying with COPPA: Frequently Asked Questions. In here it states a lot of things, mainly vague things, but what stood out to me is that they kept repeating the following: collecting, using, or disclosing personal information from children under 13. And I think this explains what COPPA is and stands for: they want websites, online services, and mobile apps to not collect, use, or disclose personal information from children under 13. This seems mainly to protect children from targeted advertisements: recognizing that younger children are particularly vulnerable to overreaching by marketers and may not understand the safety and privacy issues created by the online collection of personal information. 

Very specific and weird rule, especially considering that the FTC does not seem to care about the rest of the population of the planet whose data gets mined and sold as if it's free real estate, but I will keep that for another future article.

But then something came to mind. When did the FTC implement these rules? It seems like a very recent development, but wait... it isn't. On the FTC website it states that the last time the COPPA FAQ was edited was on March 20, 2015.

I read the entire COPPA FAQ btw, and found out some more in-depth information which makes me believe that most content creators on Youtube wont be in trouble with the FTC directly (more on that later). That said tho, Youtube surely is going to make the life of many of their content creators very difficult after getting in trouble with the FTC this year: Google and YouTube Will Pay Record $170 Million for Alleged Violations of Children’s Privacy Law.

I would say read the press release I linked because it is a hoot. It basically describes how Youtube did not want to acknowledge that certain content creators, or parts of their website, were targeting kids. Yes, you read that right: Youtube, who literally has a YOUTUBE KIDS APP, who told their creators to be more "child-friendly" refused to acknowledge towards the FTC that their website provides content that are specifically targeting children. Oh boy. 

In the press release they also note that Youtube told big toy companies like Hasbro and Mattel in presentations that "YouTube is the “#1 website regularly visited by kids" and "YouTube is today’s leader in reaching children age 6-11 against top TV channels". I swear, I am not making this up.

Of course, someone caught wind of Youtube's misbehavior and reported it to the FTC, who investigated Youtube, and ultimately fined them for $170 million. Next to that, there is a proposed settlement that Youtube (and Google) have to implement a system "that permits channel owners to identify their child-directed content on the YouTube platform". The changes we see happening now are literally because of Youtube's incompetence to obey the law.

To complete my research I went to Wikipedia's "Children's Online Privacy Protection Act" entry. I found out that COPPA was enacted in 1998 and became effective in the year 2000. So this means that Youtube had almost 20 years to implement the COPPA rules, which is funny because Youtube only exists for 14 years. I don't know what amateur lawyers Youtube has hired, but wow, have they not been doing their job. 

Even Facebook acknowledged COPPA with our dear reptile king, Mark Zuckerberg, stating in 2011 that he is opposed to it (of course he is). Actually, many people find COPPA to be outdated. Youtube and Google could've acknowledged COPPA and probably worked together with the FTC and propose a more updated version, but since they'd rather just look away like a stubborn cat, and pretend it doesn't exist, all content creators are now going to pay for it.

What many people don't understand about COPPA, and one of the reasons why they are freaking out, is because COPPA is so damn vague. But after I did some more digging (cough comprehensive reading cough) I started to realize what it all exactly means.

What mainly got the ball in my head rolling was when I read this on their Wikipedia entry:

In February 2004, UMG Recordings, Inc. was fined US$400,000 for COPPA violations in connection with a web site that promoted the then 13-year-old pop star Lil' Romeo and hosted child-oriented games and activities, and Bonzi Software, which offered downloads of an animated figure "BonziBuddy" that provided shopping advice, jokes, and trivia was fined US$75,000 for COPPA violations.

But also looking into the FTC cases against the following companies:

The FTC has brought a number of actions against website operators for failure to comply with COPPA requirements, including actions against Girls' Life, American Pop Corn Company, Lisa Frank, Inc., Mrs. Fields Cookies, and The Hershey Company.[17]

When looking at all these examples I found out that the FTC was very specific about why they fined these companies; all these companies had something specific that would attract younger kids and harvest their data. Mrs. Fields and Hershey, for example, had websites mainly targeting general audiences. However, parts of Mrs. Fields site "offered birthday clubs for children 12 or under and provided birthday greetings" and Hershey had candy-related sites that were directed to children, and both failed to meet the COPPA standards to obtain parental consent to harvest the child's data.

All these companies could've evaded fines if they would've properly complied with COPPA's rules, but usually would half-ass it or knowingly hold on to personal information, instead of deleting it, of children under age 13 without first obtaining parental consent.

It is very clear that the FTC is mainly targeting companies who consciously hold on to data they have collected from children under the age of 13, or companies who consciously market to children under 13 but don't comply to COPPA.

To translate this back to Youtube I see it as this:

Does NOT have to comply with COPPA: A kid under the age of 13 might click on a Lets Play from a Youtuber because they recognize the game in the thumbnail. The video is just the Youtuber playing the game, being themselves, and talking like a normal person, maybe making adult jokes here and there.

Does have to comply with COPPA: A kid under the age of 13 will more likely click on a Lets Play from a Youtuber because the thumbnail is very colorful with animated characters that are mainly targeting children. The video is a younger Youtuber playing a game directed at children in a child-like manner and using simple or dumbed-down language.

I kind of failed to properly describe the does have to comply with COPPA one because to me it seems so clear that it is about content that is very clearly targeted towards kids, or content that can easily be confused as kids content. This is how I understand the FTC ruling. Youtube on the other hand is more vague on how they imply the FTC's ruling, and I think we have to wait and see how it plays out. I think overall most channels will be just fine.

In conclusion,

According to many, many, many news websites Unilever is threatening to pull their advertisements from websites which do not properly handle toxic content and fake news. Some of these news websites are reporting that "Unilever threatens to pull advertisements from Facebook and Google" but that's not completely true, since their marketing director Mr. Weed (yes that is his real name: Keith Weed), didn't specify which platforms Unilever is pulling their advertisements from, but it is pretty clear that this is an open letter to Facebook and Google.

Now, many might think that this is a smart move from Unilever. I mean, they were the second biggest global advertiser in 2017. That is pretty hefty. They probably really care about their brand. Mr. Weed wrote in his speech:

"Unilever, as a trusted advertiser, do not want to advertise on platforms which do not make a positive contribution to society,"

and

“Consumers don’t care about third party verification. They do care about fraudulent practice, fake news, and Russians influencing the U.S. election,” Weed plans to say. “They don’t care about good value for advertisers. But they do care when they see their brands being placed next to ads funding terror, or exploiting children.”

That's really fucking cute coming from the mouth of Unilever! "A positive contribution to society". Dear Unilever, where is your positive contribution to society? You unnecessarily test your products on animals, you pollute waters, and you are a big contributor to destroying the rain forest and yet you dare to talk about these two tech giants, without naming them cause you are a little bitch, telling them that they don't positively contribute to society? You are literally DESTROYING THE EARTH. But I guess you can't see your own hypocritical behavior when you can only see dollar signs.

Unilever all of a sudden cares that their brand name is anywhere close to terror or exploiting children while they pull off practices that are as evil as the ones they are afraid to be connected to.

Seems to me that Unilever is just scared that their brand is associated with something bad and people will look into the brand and during their research they will find out that Unilever is as evil as can be. I don't know if Mr. Weed the marketing director is aware of these Unilever practices but his speech just comes off as hypocritical and otherwise quite ignorant.

Next to the fact that Unilever, an evil brand, tries to tell tech giants and their creators/users what is acceptable and what isn't is laughable at best too. Unilever advertises on television. They advertise on FOX News; the biggest bullshit news source that exists, but you don't hear them making demands over their backs.

I think Facebook and Youtube need to scoff at big brands wanting to pull their ads. Fuck em. The future of advertising doesn't lay in the television landscape but on the world wide web. Both Facebook and Google are the biggest brands on the internet. Unilever can't just make demands like this. Facebook and Google need to call out Unilever for their hypocrisy and tell them that if they don't like it that they can go somewhere else with their advertisements. I mean, where else can they advertise if not on Facebook or Google; Bing? Yahoo? Myspace? If you don't advertise on Facebook or Google you are missing out. Both tech giants should kick big companies to the curb and tell them to take a seat and know their place. They need to stop bending over backwards for the $$$. As long as both platforms are doing well, these big brands will scour back. Facebook and Google need to stop acting like complete doormats for these big advertising brands, especially Google. Youtube is constantly being under attack because advertisers don't get what they want. Guess what: life isn't about you and this is the internet. It is free for all. Either you adapt or you leave. Take a pick.

I find it fine that advertisers want to call out platforms where they advertise when things are going haywire. But they all act like platforms have to meet their demands, like a bunch of bullies. And they keep bullying because no one is stopping or speaking up to them. Fight back a little and tell them to know their place. No one and nothing is perfect, everything will have imperfections and will need improving. Advertising companies need to understand this and stop thinking that they can change the world by pulling their advertisements. Maybe they need to take a step back and look at their own companies and fix shit there before trying to tell other companies what to do and fit their little agenda of perfection.