In the wake of a new Adalytics report indicating that ads in Google kids’ channels may be leading to collection and distribution of children’s data without parental consent, the research firm is advising YouTube advertisers to assess their potential exposure.

“In our analyses and work with both brands and agencies, we have yet to come across a single brand or agency whose ads were not served on ‘Made for Kids’ YouTube channels,” Adalytics Founder Krzysztof Franaszek said in a just-released, in-depth interview with VAB Executive Vice President Danielle DeLauro.

“For every brand or agency that spends upwards of $1,000 USD on YouTube ads, we observed evidence of ads served on ‘Made for Kids’ videos and clicks originating from viewers of those specific channels,” he added. “As such, we advise everyone to assume they were affected. The questions then become “How much was my brand or agency affected?” and secondly, “What is my organization’s risk tolerance?”

The issues identified in the report — which are detailed, along with Google’s response/denials, in today’s MediaPost Policy Blog — “appear to affect every YouTube media buyer without exception,” he said during the interview, later adding: “Our report’s methodology section explains in detail how brands can analyze their own placement, demographic, and audience reports, and we encourage them to do so.”

Franaszek underscored the report’s disclaimer that it is “not a legal document, is not intended to provide legal advice, and does not make any allegations or claims that any laws were violated.” The report is “meant to be viewed as a highly preliminary observational analysis of publicly available information and empirical data,” he told VAB. “It is worth noting that the report may also be of interest to brands as it relates to potential financial or reputational risk; the findings do not exclusively emphasize COPPA [the federal Children’s Online Privacy Protection Act] or legal compliance.”

Asked to summarize the report’s findings, Franaszek said that “the top line is that YouTube ad campaigns from all media agency holding companies and many Fortune 500 and FTSE100 brands are being served on ‘Made for Kids’ YouTube channels. Furthermore, ad campaigns that employ demographic and behavioral (interest) ad targeting appear to still serve on ‘Made for Kids’ YouTube channels.”

Google’s policies preclude use of demographic and behavioral targeting on its kids’ channels, but do allow contextual targeting.

In June, Adalytics released a separate report that concluded that Google had been violating its own standards for placing ads bought through its TrueView platform as skippable, in-stream formats about 80% of the time.

Google has responded to both reports by challenging Adalytics’ methodology, calling them “flawed,” and saying that many of their claims about Google’s practices are inaccurate.

Google’s response to the second report includes an unequivocal denial that it has used cookies for any purpose prohibited by COPPA. 

(August 24, 2023), two U.S. senators Ed Markey (D-Mass.) and Marsha Blackburn (R-Tenn.) sent a letter to Federal Trade Commission Chair Lina Khan citing the findings in Adalytics’ new report and asking that the agency investigate whether YouTube and Google may have violated COPPA.

Founder of the “ad quality and transparency” platform stresses that its new report is a “preliminary analysis” of data and does not offer legal advice or allege that any laws have been violated.