Parking your child with a tablet and the LittleBabyBum YouTube channel may not be as kid-friendly as it seems, a group of consumer advocacy groups told the Federal Trade Commission in April.

More than 20 groups, including the Electronic Privacy Information Center, Public Citizen, and the Consumer Federation of America, asked the FTC to investigate the video streaming service YouTube for alleged violations of the Child’s Online Privacy Protection Act (COPPA). The groups claim that, even though YouTube is designated for an audience aged 13 and older, the service nonetheless directs content and advertising to children under the age of 13 and collects their personal information without providing notice to and receiving proper consents from parents.

The complaint cites a 2017 study finding that 80% of U.S. children ages 6-12 use YouTube daily, including popular channels featuring kids’ music and cartoons.

“YouTube also has actual knowledge that many children are on YouTube, as evidenced by disclosures from content providers, public statements by YouTube executives, and the creation of the YouTube Kids app, which provides additional access to many of the children’s channels on YouTube,” the complaint alleges. “YouTube even encourages content creators to create children’s programs for YouTube. Through the YouTube Partner Program, YouTube and creators split revenues from advertisements served on the creators’ videos.”

The groups state that, as disclosed in YouTube’s privacy policy, the service collects personal information including geolocation, unique device identifiers, mobile telephone numbers, and persistent identifiers that track users over time and across the Internet. Since children are using the service, they are being tracked as well, they allege.

COPPA requires that parents receive notice of such information collection and provide verifiable parental consent before such online data processing concerning their children may take place.

The FTC and YouTube are in the process of considering the complaint.

Takeaway: Consumer advocacy groups as well as regulators are vigilant about COPPA compliance and may blow the whistle if they feel it is warranted. Furthermore, advertisers should keep in mind that, if they are actively offering child-directed content, they may not have a good argument that they are not aware that their website serves children. With such awareness comes the obligation of COPPA compliance.