A group of child advocates is asking the Federal Trade Commission (FTC) to investigate Google's YouTube Kids app, claiming it is unfair and deceptive marketing geared to children under five.
The 12-page letter of complaint, which was submitted to the FTC by a coalition of medical and child safety advocacy groups on Tuesday, alleges that the app makes use of at least three types of deceptive marketing: it offers videos that contain an illegal mix of content and advertising aimed at children; much of the "user-generated" content fails to disclose relationships between the user and the manufacturers of the products endorsed in the videos; and much of the content violates the advertising policies of Google as well as the app itself.
“There is nothing 'child friendly' about an app that obliterates long-standing principles designed to protect kids from commercialism,” said Josh Golin, Associate Director of Campaign for a Commercial-Free Childhood. “YouTube Kids exploits children’s developmental vulnerabilities by delivering a steady stream of advertising that masquerades as programming."
Other signers of the complaint include the Center for Digital Democracy, American Academy of Child and Adolescent Psychiatry, Consumer Watchdog, and Public Citizen.
Alleged Violations of FCC Policy
Since the early 1970s, the Federal Communications Commission has regulated the amount and content of advertisements that can be directed at children. The core principle, the commission said, was that "basic fairness requires at least a clear separation between the program content and the commercial message so as to aid the child in developing an ability to distinguish between the two." These rules were created by the FCC because it governs the airways. However, there is no similar agency that has jurisdiction over Internet content.
The complaining organizations allege that the YouTube Kids app fails to maintain the necessary separation between content and advertising. For instance, the app offers kids "channels" that are devoted to various children's TV shows. When a "channel" is selected, the child can choose from a number of different videos. In many instances, however, the available videos are actual TV commercials for products. In addition, the YouTube Kids app often runs actual ads before playing selected clips.
As the letter to the FTC points out, children are particularly vulnerable these days to abuses by marketers of toys, games, television shows, movies, and food products.
"[R]esearch has reinforced the conclusion that children under five do not understand that advertisements are distinct from programming," the organizations noted, "[A]nd even when children can recognize the difference between ads and programming, they cannot understand that the ads are trying to sell them something, which renders them uniquely vulnerable to commercial influence."
The potential for abuse is heightened by the fact that so many young children have access to and use mobile electronic devices. According to the American Academy of Pediatrics, the recommended screen time for children under 2 is 0 hours; however, the average age at which a child first uses an electronic device is 10 months and falling. And roughly 70 percent of children ages 2-5 use tablet computers. These young viewers don't directly control purchases, of course, but they do have influence and aren't afraid to use it.
“In today’s digital era, children deserve effective safeguards that will protect them regardless of the ‘screen’ they use,” said Jeff Chester, Executive Director of the Center for Digital Democracy. “In addition to ensuring that Google stops its illegal and irresponsible behavior to children on YouTube Kids, new policies will be required to address the growing arsenal of powerful digital marketing and targeting practices that are shaping contemporary children’s media culture -- on mobile phones, social media, gaming devices, and online video platforms.”
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