The recent enforcement action against Oath’s ad exchange (formerly known as AOL) for breaching COPPA has put a spotlight on programmatic advertising to children. The case highlighted some important issues including the fact that using the ‘COPPA flag’ does not work. In fact, the only guaranteed way for advertisers to be compliant in programmatic ad buying is through a dedicated kidtech solution.
There are two approaches to enable COPPA-compliant programmatic advertising;
- Use manual COPPA flagging mechanisms and contractually oblige all upstream partners to respect it, i.e. to disregard personal information passed up in ad requests. This was the historical default approach (in the absence of any technology solution).
- Use a specific kidtech solution to prevent any personal data (including persistent identifiers and geolocation) from being transmitted in the first place.
Relying on COPPA flagging mechanisms: Not recommended
The Oath fine showed that companies cannot rely on the COPPA flag in the delivery chain (the first method). Although it may remove legal liability from some parties, it cannot guarantee that children’s data isn’t being collected (and led to very negative publicity for all companies in the chain such as Playwire and Neutrino Media).
How to guarantee data privacy protection
The only way to guarantee data privacy protection is to take the second approach — either to buy only inventory that has been made COPPA-compliant at source (thus preventing any other party from tracking kids), or to apply a kidtech filter that removes personal information in the buying systems. This is especially important for agencies who are often the most vulnerable party in this chain.
All inventory in our AwesomeAds Marketplace (which is purchasable via Rubicon and AppNexus) passes through our KidSafe Filter, which automatically strips out personal information from ad requests, preventing scenarios like the Oath situation from happening. Buyers can buy this inventory using any buyside system without needing to worry about personal data collection.
Our KidSafe Filter is also available as a separate solution which ad buyers can deploy across all their purchase of kids’ inventory, even if they are buying programmatically from other sources. It can be used alongside any buying platform to ensure ad tags (even including third-party trackers) are made fully compliant with COPPA.
Get in touch to find our more about our kidtech solutions to both programmatic and direct advertising to kids.
Max Bleyleben is Managing Director at SuperAwesome.
