Google responds to PMax and brand safety concerns

Google has responded to safety concerns regarding its Performance Max product.

The search engine came under fire after its platform YouTube was accused of improperly tracking children for targeted advertising purposes in a study conducted by Adalytics.

Brands using its PMax product may have inadvertently violated the Children’s Online Privacy Protection Act (COPPA) as a result, according to the research.

However, Google has denied the claims, suggesting there has been a misunderstanding.

Why we care. If brands are found to be in violation of COPPA, they may have to pay a significant financial penalty just as YouTube did in 2019 when it spent a record $170 million to settle similar charges.

What has Google said? Ginny Marvin, the Google’s Ads product liaison officer, said:

• “There’s been some confusion about brand safety controls and reporting supported in PMax. So I want to share a rundown of important levers available to help you control the types of content your PMax ads can appear next to in Search, Shopping, Display & Video inventory.”
• “First up, Search and Shopping suitability controls. New PMax campaign-level brand exclusions prevent your ads from serving for specific brand queries in Search and Shopping – Account-level negative keywords prevent your ads from showing for those queries in Search & Shopping.”
• “Next up, Display and Video suitability controls PMax supports *all* of your account-level content suitability settings – available from the Tools icon in Google Ads:
  • Content labels allow you to narrow the maturity level of YouTube & GDN content your ads can show on or next to. This is where you’ll find the one-click “content suitable for families” option, for example.
  • Inventory type – expanded, standard, limited – allows you to quickly choose the type of content best suited to your brand on YouTube & GDN. – Content type exclusions prevent ads from showing on certain areas of video content such as live streaming or embedded YouTube video.
  • Sensitive content categories allow you to exclude certain types of GDN content such as tragedy and conflict. – Exclude up to 1000 content keywords to prevent ads from showing on YouTube & GDN content related to those exact words.
  • Placement exclusions prevent your ads from showing on specific YouTube and GDN content. PMax respects account- and MCC-level placement exclusions. For more on content suitability controls see
• “PMax placement reports show the sites & apps where your ads appeared and are built expressly for GDN brand safety tools. They can be found in the Reports editor in Google Ads.”
• “Hope that’s helpful & please share any questions! Also worth noting YouTube & publisher content must meet Google’s content guidelines to be eligible for monetization. And YouTube has MRC brand safety accreditation for in-stream video ads.”

The fallout: In response to the findings, IPG Mediabrands conducted its own investigation. The company reportedly found that at least one of its clients, which was running an adult-targeted campaign, had its ad feature on a “made for kids” channel. If a child had clicked on the ad, tracking pixels from the brand’s website would have gathered data from the child as well as their associated ID. This data would then have been shared with Google’s PMax.

IPG Mediabrands, which manages $40 billion in marketing investment worldwide, reportedly concluded that a full investigation was needed to identify the full extent of the impact on its clients. However, in the meantime, it issued a “privacy alert” email to clients, advising them to temporarily pause campaigns using Google’s PMax.

Were any laws been broken? Under COPPA, online services must get parental consent before collecting data for targeted advertising purposes from children under the age of 13.

Adalytics researchers claim they identified the platform serving personalized ads from more than 300 brands on “made for kids” videos, which if true, would be in violation of privacy laws. When viewers clicked on these campaigns, they were redirected to the brand’s website, which sometimes resulted in dropping cookies on the user’s browser.

What is COPPA? Under US federal law, COPPA regulates the online collection and use of personal information from minors under the age of 13. It is enforced by the Federal Trade Commission. The rules apply to commercial websites and digital services that either:

• Are directed to children under 13 years of age.
• Know they are collecting personal data online from children under 13 years of age.

What has IPG Mediabrands said? A spokesperson for IPG Mediabrands told Search Engine Land that the email was an “early, unapproved draft of an internal-only note that was not reflective of our broader organizational POV. This was retracted. This was not sent to clients.”

The email in question – which was obtained by Business Insider – read:

• “Because placement reporting is not available for PMAX, we recommend that clients temporarily pause PMAX until the efficacy of the above controls are validated on non-PMAX campaigns where placement reporting is available.”
• “Clients should consult with their legal, privacy/infosec, website, and data teams to consider potential exposure, and determine the appropriate process for identifying and removing data potentially collected from children.
  For example, advertisers may assess data in their CDPs that originated from YouTube as a traffic source.”
• “These recommendations are being made on the basis of the probability of FTC scrutiny, as well as in light of the evidence of waste in advertising investment against unintended audiences.”

Deep dive. Read Adalytics’ YouTube study in full for more information on its research. Read Google’s official documentation on how ads work on YouTube for supervised accounts for more information.

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