YouTube is the most popular video-sharing website and application consisting of user-generated content (UGC). The platform is formally restricted to people 13 and older, but its popularity with younger children is knowingly growing. Given this fact, the concern over children’s safety on YouTube is also increasing, and advocates encouraged the Federal Trade Commission (FTC), a United States government's independent agency, to investigate YouTube practices.
In September 2019, the FTC claimed that YouTube illegally collected personal information from children without their parents' consent, violating the Children's Online Privacy Protection Act (COPPA) rule. To settle the allegations, Google and YouTube were required to pay a $170 million fine and implement a system to allow channel owners to identify if their content is child-directed, along with other measures.
Since then, YouTube has completely restructured their system and creators were required to inform if their videos are children-directed or not. Indicating the content as "made for kids" causes several restrictions on the video and channels levels and reduces their revenue. The FTC also declared that COPPA Rule applies to YouTube channel owners in the same way it would if they had a website or app and, therefore, they may face civil penalties if they fail to set their audience accurately.
The event caused a big commotion in the YouTube community and became a subject of lively discussion amongst users and channel owners that are worried about their future on the platform. Many creators published videos questioning, explaining, criticizing, or sharing their concerns about the topic. Alongside, the FTC requested public comment on the implementation of the policy, and the open forum received massive public participation, with submissions totalizing more than 176.000 comments.
The way the COPPA Rule is currently being implemented will set the parameters for future application of that and other online privacy policies. Therefore, it is crucial to identify potential impacts and understand the outcomes from the perspectives of the various actors interested in the matter.
The present research aimed to understand the implications of the recent COPPA Rule implementation on the children's content ecosystem on YouTube, identify its potential impacts on the various actors, and uncover opportunities to improve that policy's implementation in the future. More specifically, the study intends to answer the following questions:
RQ1: Who are the actors with a vested interest in the COPPA Rule application on YouTube, what are their positions, and what are the perceived risks, challenges and opportunities to them?
RQ2: How did the COPPA Rule's implementation process impact creators, and how can it affect the future of the children's content ecosystem on YouTube?
RQ3: How can the COPPA Rule and its implementation mechanisms be improved to minimize the risks and potentialize the opportunities perceived by the various actors?
The research consisted of an extensive literature review and a detailed content analysis of comments, videos, official communications, and documents related to the recent COPPA Rule’s implementation on YouTube. The methodology combined three different methods and data sources in order to investigate the phenomena from multiple perspectives:
- Study 1:
This approach focused on identifying which creators are being heard on YouTube regarding the COPPA rule’s implementation, how they perceive the existence of impacts of that implementation on the community, and which strategies they utilized to get the attention and share their message. In this part of the study, nonprobability sampling and fixed coding were used to select and analyze 80 videos. The coding categories were predetermined to allow the characterization of the video’s host, channel and message characteristics.
- Study 2:
This approach focused on identifying the perceived impacts and solutions from the creators' point of view that eventually had some or all of their videos affected by the new YouTube system for complying with COPPA. A total of 15 videos were selected through purposeful sampling with a combination of criterion and maximum variation approaches. Those videos were transcribed, and a flexible coding methodology was applied to inductively analyze their content using the software NVivo 12 for Windows.
- Study 3:
This approach focused on identifying opinions, perceived impacts and potential solutions from the point of view of parents by examining comments retrieved from the FTC’s open forum docket. A total of 230 comments were selected and coded using the same content analysis procedure utilized in Study 2.
The main findings of each part of the research are presented within the following three sections.
- Study 1: Which creators are getting the attention?
The videos' hosts were characterized by the type of presentation (person, voice-over, animation, or text), gender, and race. More than half of the videos were presented by one or more people speaking in front of the camera, at least in part of the video. The hosts were mostly white (81%) and male (80%),
The channels to which each of the videos belongs were characterized by category, size, and the presence of content defined as "made for kids". Some creators had more than one video in the sample, so the 80 videos belonged to 63 channels. The most frequent categories were “Gaming” (26%) and “Legal” (16%), and the majority of the videos (66%) belonged to channels that had less than 100,000 subscribers at the moment of sampling.
Just over half of the sampled videos had thumbnails constituted of elements that evoke negative feelings, and 70% portrayed COPPA as negative or shared a pessimistic view about its potential impacts on YouTube or a specific community. Three-quarters of the videos used emotional appeal, especially fear and anger, to convey their message, and half of them used some type of call-to-action to encourage the viewers to act in order to interfere with the COPPA rule implementation on YouTube.
- Study 2: Which creators are being affected, and how?
As in Study 1, the selected videos' hosts were characterized by the type of presentation (e.g. person, voice-over), gender, and race. Most of the videos were presented by one or more people speaking in front of the camera, and the majority of the hosts were white (84%) and female (67%).
Each of the selected videos belonged to a different channel, most of them being categorized as “People & Blogs” and “Film & Animation”. About half of the channels had less than 100,000 subscribers at the moment of sampling. Only 20% of the creators affirmed that they had children as their primary targeted audience while creating content. However, most of them acknowledged that children watch their channels (87%).
As a result of the flexible coding content analysis, the most relevant impacts that creators identified as potentially affecting creators were related to:
- Uncertainty, anxiety, and fear;
- The risk of losing revenue; and
- The need to change their content.
The most significant impacts that creators perceived to potentially affect audiences were:
- Loss of content quantity, variety and quality;
- Lower ability to communicate and engage;
- Exposure to more mature and inappropriate content.
Creators proposed the adoption of other platforms, asked their audiences to search for new videos actively, and also suggested that parents should decide which content their kids' access, creators should find another sources of revenue, and YouTube should updated their Terms of Service to request parents’ consent for data collection as a solution for the issues caused by the recent COPPA Rule implementation on YouTube.
- Study 3: What are the parents’ opinions?
Parents' gender was determined as a father or as a mother by considering their self-identification within the comments under analysis. A total of 91 parents were self-identified as mothers (40%), and 35 were self-identified as fathers (15%), while the other 104 did not specify their gender.
As a result of the flexible coding content analysis, the most relevant impacts that parents identified as potentially affecting creators were related to:
- The risk of affecting channels that are not aimed at kids;
- The risk of losing revenue; and
- The risk of losing their job or businesses.
The most significant impacts that parents perceived to potentially affect audiences were:
- Loss of content quantity, variety and quality;
- Exposure to more mature and inappropriate content; and
- The risk of getting irrelevant or inappropriate ads.
While many parents agreed that they should be in control of what their children access on the Internet, the most proposed solution to overcome the COPPA rule issues was the elaboration of clearer guidelines for compliance.
While it is important to protect children's online data, rules such as COPPA may have unanticipated impacts. The application of that rule on YouTube caused anxiety, uncertainty and fear on the platform community, as it may negatively affect creators and viewers, especially children.
According to this study’s findings, both creators and parents believe that the ability of children's content creators to generate revenue will significantly decrease. The results suggest that the COPPA rule’s implementation on YouTube will harm creators’s abilities to build a career, potentialize the issue of gender inequality on the platform, and benefit big companies, contributing to the return of the status quo ante.
Independent creators may be discouraged from starting or continuing to create children content, either abandoning their channels or switching their content strategies toward an older audience. As a consequence, the production of the children-directed content may decrease in quality, quantity and variety.
Many parents think that they should be in control of what their children access online, and that by reducing the availability of appropriate content on YouTube, COPPA will undermine their ability to make choices. Their children will either lose access to online content or be exposed to more mature videos and ads. Thus, there is a need to find solutions that will protect children without increasing provision and participation gaps.
In conclusion, there are pros and cons of the application of the COPPA Rule on YouTube. The law is currently under review, and the regulatory approach needs to aim for a balance between protecting children's online privacy and preserving the platforms' sustainability, to contribute to the universal access to diverse and high-quality digital resources for children.