Advocates say Google/YouTube Violates Federal Law and Children’s Privacy Law

Image result for kids watching youtube80% of kids aged 6-12 watch YouTube yet parents are never asked for their consent before Google collects their personal data, as required by the federal law called COPPA.

Here is the complaint filed today to the FTC, demanding that they make Google/YouTube comply with the law , led by Center for a Commercial Free Childhood and signed onto by 22 advocacy groups including the Parent Coalition for Student Privacy.  The complaint was covered by the NY Times, Wired, the Guardian, the Associated Press, USA Today, and  Consumer Reports.

The press release is below.

Monday, April 9, 2018

Contact: 

Jeff Chester, CDD ([email protected]; 202-494-7100)
David Monahan, CCFC ([email protected]; 617-896-9397)
Angela Campbell, IPR ([email protected]; 202-662-9541)
Kara Kelber, Consumers Union ([email protected]; 202-462-6262)
Lisa Cohen, Common Sense ([email protected]; 310-395-2544)

Advocates Say Google’s YouTube Violates Federal Children’s Privacy Law 
Consumer, privacy and children’s groups file complaint urging FTC to stop most popular kids’ online video service from gathering children’s data

WASHINGTON, DC—April 9, 2018—Today, a coalition of leading U.S. child advocacy, consumer, and privacy groups represented by the Institute for Public Representation filed a complaint urging the Federal Trade Commission (FTC) to investigate and sanction Google for violations of the Children’s Online Privacy Protection Act (COPPA) in operating YouTube. Google claims that YouTube is only for users 13 and up, despite being the most popular online platform for children, used by 80% of American children ages 6 to 12. The site features many programs designed and promoted for children and Google generates significant profits from kid-targeted advertising. The complaint says the FTC should subject Google to penalties, which could total in the billions of dollars.

The Center for Digital Democracy (CDD), Campaign for a Commercial-Free Childhood (CCFC), and 21 other organizations demonstrated in their filing that Google, which owns YouTube, makes substantial profits collecting many types of personal information on kids on YouTube, including geolocation, unique device identifiers, mobile telephone numbers, and persistent identifiers used to recognize a user over time and across different websites or online services. Google collects this information without first providing direct notice to parents and obtaining their consent, and Google uses it to target advertisements to kids across the internet, including across devices. COPPA bars the operator of a website directed to children, or that has knowledge of children using it, from collecting and using such information without obtaining parental consent.

CCFC’s Executive Director Josh Golin said, “For years, Google has abdicated its responsibility to kids and families by disingenuously claiming YouTube—a site rife with popular cartoons, nursery rhymes, and toy ads—is not for children under thirteen. Google profits immensely by delivering ads to kids and must comply with COPPA. It’s time for the FTC to hold Google accountable for its illegal data collection and advertising practices.”

Child directed channels such as ChuChuTV Nursery Rhymes & Kids Songs (15.9 million subscribers and over 10 billion channel views) and LittleBabyBum (14.6 million subscribers and over 14 billion channel views) are among the most popular channels on YouTube. Major advertisers pay Google a premium to place their ads in a platform known as “Google Preferred,” which includes a “Parenting and Family” lineup comprised mostly of popular channels targeted to children.

“Google has acted duplicitously by falsely claiming in its terms of service that YouTube is only for those who are age 13 or older, while it deliberately lured young people into an ad-filled digital playground,” said Jeff Chester of the Center for Digital Democracy. “Just like Facebook, Google has focused its huge resources on generating profits instead of protecting privacy.”

Angela J. Campbell, counsel for CCFC and CDD, said: “Given the large number of children affected and the extent of YouTube’s COPPA violations, the FTC needs to impose large civil penalties to show it is serious about protecting children’s privacy online.” 

James P. Steyer, CEO of Common Sense, said: “Kids have been watching videos on YouTube for years, something the company has known, and profited off of, by targeting content and ads at children under 13. It is time for Google to be completely transparent with all the facts and institute fundamentally responsible new policies moving forward to protect the privacy of kids. We fully expect Google to work closely with advocates and reach out to parents with information about parental controls, content, and collection practices on YouTube so parents can make informed choices about what content they allow their kids to access and how to protect their privacy.”

Katie McInnis, policy counsel for Consumers Union, said: “YouTube knows children are watching content on their site, and has created content channels specifically aimed at them, but does not appear to obtain the required parental consent before collecting information about them. Google has the responsibility to be COPPA-compliant and ensure that children can safely watch the programs designed and promoted for kids. These practices present serious concerns that warrant the FTC’s attention.

Groups signing on to the complaint to the FTC along with CDD and CCFC are: Berkeley Media Studies Group; Center for Media Justice; Common Sense; Consumer Action; Consumer Federation of America; Consumer Federation of California; Consumers Union, the advocacy division of Consumer Reports; Consumer Watchdog; Corporate Accountability; Defending the Early Years; Electronic Privacy Information Center (“EPIC”); New Dream; Obligation, Inc.; Parent Coalition for Student Privacy; Parents Across America; Parents Television Council; Privacy Rights Clearinghouse; Public Citizen; The Story of Stuff Project; TRUCE (Teachers Resisting Unhealthy Childhood Entertainment); and USPIRG.

The complaint was drafted by the Communications & Technology Law Clinic in the Institute for Public Representation at Georgetown University Law Center.

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PARENT ALERT: Mathletics data leak with personal info of over 114,000 students exposed

A widely used classroom app called Mathletics produced by 3P Learning displays student first names, last initials, and schools on a public website if they’ve won enough points in online math games every week. There are hundreds of US schools participating. See the article posted below in Australian papers about this here. There was also a blog post about the data leak here.

A list of US schools that has allowing the company to post kids personally identifiable info online was provided to me a concerned Australian privacy expert; it is here . It shows that the personal data of over 114, 000 US children has been exposed since 2014. This public disclosure should ONLY be done with parent consent. Check out to see if your child’s school is on the list, and if you haven’t been asked for consent, demand this immediately.

New parent guide to online learning: check it out!

Please check out and share this new NPE guide: What Every Parent Should Know about Online Learning.

As you know, many of the software programs being used in schools have uncertain value, and can undermine student privacy, engagement and authentic learning. I hope that this guide will help chip away at some of the massive hype that has surrounded the subject of online learning in recent years.

It offers questions parents should ask their children’s schools and districts before adopting computerized programs to deliver instruction, assessment or behavior management.

It also has sections examining the efficacy of some of the most over-hyped online programs like Summit PLP, Rocketship and New Classrooms, as well as widely used online assessments like MAP and i-Ready. The press release is below.

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MEDIA ADVISORY FOR March 9, 2018

For more information contact: Carol Burris, NPE Executive Director, 718-577-3276, [email protected]


Kew Gardens, New York –
Today the Network for Public Education (NPE) released a new report, Online Learning: What Every Parent Should Know, in response to the growing dependence on technology in K-12 education. Schools are increasingly implementing digital instruction, often requiring that students use online programs and apps as part of their classwork. Many students even attend a virtual, full-time charter school, never meeting teachers or classmates face to face.

Yet there is scant evidence of educational technology’s success and growing concerns regarding its negative impact. This guide presents a frank assessment of the intended and unintended consequences of online learning in K-12 school and offers questions parents should ask principals if their child’s school adopts computerized programs to deliver instruction, assessment or behavior management.

Rachel Stickland, Co-Chair of the Parent Coalition for Student Privacy, had the following to say about the report: “NPE’s Online Learning report is essential reading for anyone questioning the research behind the national push toward digital education. With this report in hand, parents can discuss their concerns with online learning confidently with school leadership – whether it’s the lack of evidence showing that it actually works, the political and moneyed interests advancing it, or how it places student privacy at risk.”

Dr. Faith Boninger of the University of Colorado Boulder researches and writes about commercial activities in schools. Commenting on the importance of the report she said, “As much as companies are eager to sell digital technology to schools, and schools are eager to increase children’s achievement, research does not support claims that shifting to digital educational platforms achieves the desired goals. What a growing body of research does indicate, however, is that excessive computer use by children leads to negative health effects such as vision and sleeping problems, social-emotional disturbance, and addiction to digital devices. NPE’s report on on-line learning is an important, timely, resource for parents. In plain language, its review of what we know about online learning shows that parents would do well to not accept promises or bland reassurances, but rather be extremely skeptical consumers. Armed with this report, parents will be able to ask administrators the very hard questions that must be answered adequately in order to justify the use of digital technologies to teach children.”

The 18-page guide is a parent-friendly review of the research on virtual schools, online courses, blended learning and behavior management apps. It also includes a discussion of the student privacy issues that arise when highly sensitive personal student data is collected by online programs and then distributed to third-party vendors without parent knowledge or consent.

The guide’s harshest criticism is reserved for virtual charter schools, whose academic ineffectiveness, coupled with fraudulent attendance practices, resulted in NPE’s recommendation that parents refrain from enrolling their children in online charters.

Based on the report’s findings, NPE President Diane Ravitch advises parents to “be wise consumers.” According to Ravitch, “Technology can be used creatively in the classroom by well-prepared teachers. But most of what is sold as ‘digital learning‘ is a sham that allows vendors to mine student data. Worse, online charter schools are educationally worthless. Students learn best when there is human interaction between teachers and students and among students. Parents must beware of false promises by profiteers.”

Online Learning: What Every Parent Should Know is available online at https://networkforpubliceducation.org/wp-content/uploads/2018/03/Online-Learning-What-Every-Parent-Should-Know.pdf.

The Network for Public Education (NPE) was founded in 2013 by Diane Ravitch and Anthony Cody. Its mission is to protect, preserve, promote, and strengthen public schools for both current and future generations of students. We share information and research on vital issues that concern the future of public education. For more information, please visit: networkforpubliceducation.org.

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