Here are breaches of trust, safeguarding, privacy and law. They expose kids to risks of online harm and discrimination.

Charities and public services must not share kids or encourage kids to share their troubles with social media and ad systems.

Social media only allow sites to use their embeds if sites respect terms regarding age limits, parental consent and data collection.

Had these organisations paid attention to the terms, they may have realised that what they were doing was wrong.

If you are distressed by any content, please seek support. The Samaritans are available on 116 123.


Ad Tracking of Young Carers

Young carers are children who have a responsibility to help with the care of another family member.

Honeypot is a charity to help children in this situation.

When a young carer feels the desire to do some Yoga, HoneyPot offers them videos to learn how .

Sadly, those videos are hooked up to Google's Ad system and sharing personal data with Google that the user watching is probably a carer, that one of their family members is thus in need of care.... which advert is it best to show the child?

Perhaps young carers are statistically more likely to be engaged with a terminally ill people and thus a great advertising target to share details of funeral services to?

I'd hope not, but do you trust advertising systems that game towards users likely to react, to work out that in this case, it probably isn't appropriate?

Compared to sharing data about HIV, suicidal feelings, cancer and sexual abuse, this is not the worst breach here.

Since doing so in January, the ICO has advised they have closed the case and Honepot have not removed YouTube.

So what makes this case so interesting?

The DPO replied to the complaint acknowledging that their use of YouTube was unlawful, they even copied in the ICO.

Is it fixed?

No, suggesting the ICO has ignored its responsibilities and the obviousness of unlawfulness, given the admission of fault.

Raising the complaint

18th January 2023: Complaint sent to Honeypot and ICO

31st January 2023: Honeypot responded and stated:

Thank you for your email dated 18th January 2023 in which you raise concerns about the sharing of personal data of individuals who access and use our website. We apologise for the delay coming back to you.

We understand that you are concerned about cookies and personal data being shared with Google. You also have concerns about the videos that are embedded into our website and you provide an example of the YouTube yoga for children video.

Your complaint has prompted us to review our cookie banner and the information we provide more generally on cookies. We did have some information in our Privacy Policy but, in light of your complaint, we have produced and have now published a new cookie policy which sets out the use of cookies on our website and which includes links to the cookie policies of any third parties on our website. We have also updated our cookie banner so that you have a choice to either accept or reject non-essential cookies before proceeding to use the website.

In terms of your complaint about YouTube, we changed to using the privacy enhanced mode but, as you have rightly pointed out, this does not prevent cookies still being used and so we have taken the decision to remove all the YouTube embedded videos targeted at children from our website. We are now in the process of considering a more privacy friendly streaming service to display any video content going forward.

We are very sorry for any distress this has caused but you will see that we have taken your concerns seriously and taken steps to address them. If you have any remaining concerns, please do not hesitate to get in touch with us again and we thank you for bringing these issues to our attention.

29th June 2023: Complaint re-raised

Despite HoneyPot's cookie banner stating the following:

By using this website, you agree to our use of cookies. We use cookies to provide you with a great experience and to help our website run effectively. You can view our cookie policy here.

They are already sharing data with YouTube and that banner does not explain that data sharing will happen.

Meanwhile, despite the decision evident in their previous email, they have not removed YouTube.