External Data Sharing and Third-Party Processing

What it is

YouTube Kids will not share your child's individual data outside Google except with parental consent, for legal reasons, or when sharing with third-party processors who handle data on Google's behalf under confidentiality requirements.

Why it matters (compliance & governance perspective)

The external processing carve-out means that third-party vendors and affiliates may access your child's data as processors, even without specific parental consent for each such transfer, provided they operate under Google's instructions and privacy commitments.

Consumer impact (what this means for users)

Your child's data may be shared with Google's affiliates and third-party service providers for processing purposes without requiring separate parental consent for each transfer, provided those parties operate under Google's instructions. Individual data will otherwise only be shared externally with parental consent or for legal compliance reasons.

Institutional analysis (Compliance & governance intelligence)

REGULATORY LANDSCAPE: Under COPPA, operators must disclose their data sharing practices with third parties and obtain verifiable parental consent before sharing children's personal information with third parties for purposes other than internal operations. The 'external processing' carve-out described here is consistent with COPPA's operator-as-agent exception but requires that processors be contractually bound and that the data sharing be limited to internal operational purposes. The FTC is the primary enforcement authority. GDPR Article 28 governs data processor relationships for EEA users. GOVERNANCE EXPOSURE: Medium. The notice's framework for external sharing is broadly consistent with industry standard practice and COPPA's internal operations exception for processors. However, the breadth of 'affiliates or other trusted businesses or persons' is not enumerated, and compliance teams may want to evaluate the scope of the processor network and whether all such transfers are adequately covered by processor agreements. JURISDICTION FLAGS: EEA users trigger GDPR Article 28 requirements for data processing agreements with each processor. COPPA's internal operations exception applies for US users but is subject to FTC interpretation. Cross-border data transfers involving EEA child data may engage GDPR Chapter V transfer mechanisms. CONTRACT AND VENDOR IMPLICATIONS: Google's assertion that processors operate 'in compliance with our Privacy Policy and any other appropriate confidentiality and security measures' is a standard contractual framework but does not enumerate specific contractual obligations. Institutional procurement teams may want to request Google's data processing agreements or sub-processor lists for due diligence purposes. COMPLIANCE CONSIDERATIONS: Legal teams should evaluate whether the aggregate data sharing provision (sharing aggregate, non-individual data with third parties for trend reporting) is adequately de-identified to fall outside COPPA and GDPR personal data definitions. Processor agreements should be reviewed to confirm they include appropriate child data protections.

Applicable agencies

Applicable regulations

Provision details

Other risks in this policy

• App Activity Data Collection medium
• Cross-Product Data Use for Signed-In Child Accounts high
• Contextual Advertising with Interest-Based Advertising Prohibition medium
• Parental Controls and History Management low
• This Privacy Notice Overrules the Google Privacy Policy low
• Signed-In Child Profile Data Collection high

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