By: Holly Eberle
If you are a technology librarian who uses YouTube like I do, then you have been getting emails about creator content since the fall of 2019. In one such email dated January 6, 2020, YouTube made the move to become compliant with the Children’s Online Privacy and Protection Rule (COPPA). Videos now must be designated by the creator as made for kids or not. YouTube no longer serves personalized ads or supports comments, Stories, live chat, the notification bell, among other features on videos designated made for children.
For reference, the Federal Trade Commission (FTC) summarizes COPPA as the imposition of “certain requirements on operators of websites or online services directed to children under 13 years of age, and on operators of other websites or online services that have actual knowledge that they are collecting personal information online from a child under 13 years of age.”
In the January 6, 2020 email, YouTube writes that “all creators would be required to designate their content as made for kids or not made for kids in YouTube Studio, and that personal information from anyone watching a video designated as made for kids would be treated as coming from a child, regardless of the age of the user.” This protects kids from targeted advertising, data collection, and communication with other YouTube profiles — at least when kids are watching made for kids videos.
However, many YouTubers complain that it puts the burden of judgement on the creator, which in turn opens YouTube creators to FTC audits. Many do not want to lose out on their financial gain that comes with running targeted advertising on their videos. Like much of the Internet, YouTube is not as innocent as it used to be. It is the end of an era for the website.
Individuals must be 13 or older in order to create a YouTube account. In that regard, YouTube has always been compliant. The reality is that individuals younger than 13 use YouTube and therein lies the problem that got them into trouble in 2019. They made millions by illegally collecting data from minors without a guardian’s consent. They were ordered to pay $170 million by the FTC, which is historically the largest penalty given to a company for violating COPPA.
YouTube is not the only company that has sent out emails about new data collection and privacy policies. I have received similar emails from Etsy and Canva. With the California Consumer Privacy Rule (CPPA) recently going into effect, 2020 seems to be sharing up as the year for being mindful of online hygiene.
What about Libraries?
Many libraries have YouTube accounts or videos uploaded to YouTube from individual employee accounts related to library business. The Library and Information Science (LIS) profession is a bit better equipped to comply with YouTube’s new policy than a YouTuber who was not already familiar with COPPA prior to 2019.
School librarians and educators might be the most familiar LIS professionals with this legislation. The issue in school libraries is pretty black and white. For many school librarians, none of their users are older than 13 and that will never change.
Public libraries must also be mindful of COPPA legislation. It gets trickier when the population of users is comprised of infants to 100-year-olds. Public library patrons of all ages use services provided not by the library but by third-party vendors. The vendors are hired by the library but are not actually part of the library. Public library workers, are you confident with the privacy policies of all your library’s third-party vendors and how those vendors are compliant with COPPA?
As with YouTube’s new policy, many school and public librarians are on their own when assessing privacy concerns regarding the services that their library outsources to a third party…Or so one may think. Privacy is a core value of the American Library Association so no library employee is completely alone.
The Intellectual Freedom Committee’s Privacy Subcommittee, “monitors ongoing privacy developments in technology, politics and legislation, as well as social and cultural trends that impact individual privacy and confidentiality, both in libraries and the wider world.” They have developed many resources for library workers to utilize. 2020 would be a great time to conduct a privacy audit at your library! A few resources to get you started are listed below:
Holly Eberle is the Youth Technology Librarian at the Algonquin Area Public Library District in northern Illinois and a member of the Intellectual Freedom Committee. She received her MLIS from the University of Illinois in December 2015. Her passion for the intellectual freedom rights of youth began in kindergarten when her elementary school library pulled the Goosebumps series off the shelves. She also is interested in the technological realm of intellectual freedom and privacy issues. Outside of the library she is a metalhead and you may follow her on Instagram @doom_metal_librarian.