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Over 70,000 social media professionals are reading this newsletter today!
Welcome Back to TWISM’s Autopsy Series!
In this series, we examine the biggest actual marketing deaths worldwide. While others made expensive mistakes, you, along with 70,000+ professional TWISM readers, are learning from their failures for free.
Keep in mind that these weekly autopsies could save your career.
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🔬 The Main Autopsy: Disney’s “Made for Kids” Mislabeling Crisis
Patient Details
Brand: The Walt Disney Company.
Campaign: YouTube audience-labeling + monetization workflow (“Made for Kids” vs. “Not Made for Kids”).
Budget: $10,000,000 civil penalty (paid under court-approved order).
Cause of Death: Channel-level defaults were used as a shortcut where child-level compliance was required.
Time of Death: December 31, 2025 (federal judge approved the order).
What They Intended
Disney wanted to keep its massive YouTube footprint monetized while relying on YouTube’s labeling system to separate kid-directed content from general-audience inventory.
The “simple” operating model: set default channel-level audience designations and keep publishing at scale.
What Actually Happened
Regulators alleged Disney failed to properly label certain child-directed videos as “Made for Kids,” triggering COPPA compliance risk.
YouTube reportedly flagged roughly 300 videos to Disney around June 2020, yet the government alleged Disney didn’t overhaul the underlying workflow.
The alleged mislabeling enabled the collection/use of children’s data for ad purposes without the required parental notice/consent (as described by regulators).
The story didn’t die in September. It returned with a courtroom toe tag when the order was approved, reigniting coverage and industry chatter.
The Numbers
$10,000,000 civil penalty under the approved order.
Government filings describe a compliance failure involving kid-directed videos on YouTube and COPPA requirements (notice + verifiable parental consent).
YouTube’s outreach to Disney in June 2020 about ~300 videos is cited in multiple reports of the complaint.
The order requires Disney to implement a compliance program/audience designation process to prevent recurrence (per FTC/DOJ descriptions).
The FTC framed the case as about children’s data collection connected to kid-directed viewing on YouTube (not Disney’s own platforms).
Timeline of Destruction
Jan 2020: YouTube’s post-2019 COPPA era makes “Made for Kids” labeling materially consequential for data/ads (context for the ecosystem Disney operated in).
June 2020: YouTube notifies Disney about ~300 videos needing “Made for Kids” treatment (as described in coverage of the complaint).
Sep 2, 2025: FTC announces the proposed settlement and $10M penalty.
Dec 30, 2025: Coverage spreads as the agreement finalizes in court.
Dec 31, 2025: Federal judge approves the order; the autopsy becomes an official record.
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🧬 Failure DNA Analysis
The Root Cause: “Operational Convenience Over Legal Anatomy”
This wasn’t a creative fail; it was a workflow fail. The patient didn’t bleed out from a bad tweet. It bled out from a process design that treated compliance like metadata instead of medicine.
Cognitive Bias #1: Automation Bias
When a platform offers toggles, defaults, and labels, teams over-trust the system and under-invest in human review, especially at scale. The Disney case is explicitly about how audience designation was handled and what was enabled on YouTube.
Cognitive Bias #2: Normalcy Bias
“If we’ve been publishing this way for years, it must be fine.” The allegations describe an extended gap between warning signals and a redesigned process.
Warning Signs They Ignored:
A platform warning about mislabeled kid-directed videos is not “FYI”, it’s a siren.
COPPA doesn’t grade on a curve for operational scale; it’s strict about notice/consent obligations.
“Channel defaults” are tempting precisely because they hide edge cases, a.k.a. the cases regulators love.
Anything involving kids’ data turns small config decisions into reputation-level liabilities.
Why Smart People Made This Dumb Decision:
Publishing teams optimize for throughput. Legal teams optimize for risk. When those systems don’t share a single checklist, and “default settings” become the handshake, nobody is malicious, but everyone is exposed.
The settlement’s mandated program is basically a forced organ transplant: build a durable compliance workflow, not a one-time fix.
🎭 Myth Busted: “The Platforms Handle Compliance”
The Myth: If you upload to YouTube and pick a default audience setting, the platform will keep you compliant.
The Reality: Regulators alleged Disney’s labeling choices enabled unlawful collection/use of kids’ data for ad purposes, meaning the liability followed the content owner, not just the platform.
Data Points:
Disney paid $10,000,000 under the order.
Reports describe YouTube flagging ~300 videos back in June 2020: a clear signal that defaults weren’t enough.
The court-approved settlement requires a compliance program/audience designation process; the “platform will handle it” myth is a fantasy.
Why This Myth Persists:
Because it’s emotionally soothing. “The platform has guardrails” feels like outsourcing guilt. But regulators treat kids’ privacy as a high-priority organ system: touch it, and you’re in triage.
What to Do Instead:
Treat audience labeling as a controlled medical procedure: documented decisions, second checks, and audit trails, especially for child-directed content.
🛡️ Failure Prevention Toolkit: The “Kid-Directed Content Triage Checklist”
Before you publish or monetize kid-adjacent content:
✓ Governance
Assign a single accountable owner for “kid-directed” determinations (not “everyone,” not “the platform”).
Create a written decision rubric aligned to COPPA concepts (kid-directed triggers, review frequency).
✓ Labeling Operations
Require per-video review for any kid-adjacent channel; never rely solely on channel defaults.
If the platform flags content, treat it like a severity-1 incident: fix, document, and retro-audit the back catalog.
✓ Monetization Hygiene
Map exactly which ad products can run against kid-directed inventory and ensure your teams can’t “accidentally” re-enable risky options.
Keep a change-log of monetization settings tied to content categories.
✓ Audit & Proof
Run quarterly spot-checks and keep evidence (screenshots, exports, timestamps).
Build a pre-mortem: “If a regulator asked tomorrow, could we prove why we labeled this video NMFK?”
Red Flags to Watch For:
“We’ll fix it later, publishing comes first.”
“It’s Disney/Big Brand; they won’t care.” (They did.)
“The platform warning was just an automated email.”
“Our defaults are set, ship it.”
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