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SettlementHigh Risk

FTC Fines Disney $10M for COPPA Violations via YouTube Mislabeling

Disney Worldwide Services, Inc. and Disney Entertainment Operations LLCDecember 31, 2025Federal Trade Commission

Penalty Amount

$10,000,000

Summary

The FTC settled with Disney for violating the COPPA Rule by mislabeling videos on YouTube, which allowed the collection of children's personal data without parental consent. Disney must pay a $10 million civil penalty and implement measures to ensure proper video labeling and compliance with COPPA.

Remedy

Disney must pay a $10 million civil penalty, comply with COPPA by notifying parents and obtaining verifiable parental consent before collecting children's data, and establish a program to review whether videos posted to YouTube should be designated as 'Made for Kids'.

Monetary PenaltyCompliance Program

Contract Impact

In-house legal teams should review all vendor agreements with online platforms (e.g., YouTube, social media, streaming services) and customer agreements for any child-directed services or content. Specifically, examine clauses related to data labeling responsibilities (e.g., 'Made for Kids' or equivalent designations), consent mechanisms for children's data, prohibitions on targeted advertising to children, data processing and sharing restrictions, and audit rights. Contracts must be updated to explicitly require partners to comply with COPPA labeling obligations, implement robust parental consent flows, and prohibit the use of children's data for ad targeting. Data processing addendums (DPAs) should incorporate COPPA-specific safeguards and require certification of compliance.

Contract Search Terms

Made for Kids labelingparental consent mechanismCOPPA compliance certificationdata processing addendumchild-directed content designationaudit rights for children's datadata minimization clausetargeted advertising prohibition for childrenthird-party data sharing restrictionsretention schedule for children's data

Laws Cited

COPPA Rule

Violation Types

Entity Details

Entity

Disney Worldwide Services, Inc. and Disney Entertainment Operations LLC

Also known as: Disney

Industry

Media & Entertainment

Official Sources

Source Evidence

Entity Name
"Disney Worldwide Services, Inc. and Disney Entertainment Operations LLC"
Fine Amount
"$10 million"
Laws Cited
"Children’s Online Privacy Protection Rule (COPPA Rule)"
Violation Types
"violated the COPPA Rule by failing to properly label some videos that it uploaded to YouTube as 'Made for Kids' (MFK)"

Related Enforcement Actions

FTC

Disney Worldwide Services, Inc. and Disney Entertainment Operations LLC

$10.0M

The FTC alleges that Disney violated COPPA by failing to properly label children-directed videos on YouTube as 'Made for Kids,' allowing the collection of personal data from children under 13 without parental consent. Disney will pay a $10 million civil penalty and must implement a program to ensure accurate video designations, potentially incorporating age assurance technologies.

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