FTC Revises COPPA Compliance FAQs Focusing on Apps

On the heels of its lawsuit against Amazon.com regarding in-app purchases, on July 16, 2014, the Federal Trade Commission announced revisions to three of its Frequently Asked Questions (FAQs) related to obtaining verifiable parental consent under the Children’s Online Privacy Protection Act (COPPA) Rule. 

Specifically, the revisions:

  1. Confirm that a credit or debit card need not be charged to obtain parental consent if the collection of the card number is combined with “other safeguards” (COPPA FAQ H. 5);
  2. Reiterate that a mobile app developer can rely on an app store to obtain parental consent on its behalf (new COPPA FAQ H. 16); and
  3. Reiterate that third-party platforms, such as app stores, can develop “multiple-operator” parental consent solutions for the applications that run on top of the platform, while clarifying that such offerings do not expose platforms to legal liability under COPPA (COPPA FAQ H. 10).

Given the FTC’s recent lawsuit against Amazon, the changes appear to reaffirm the FTC’s intentions to dictate when and how developers and app stores need to obtain parental consent.

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