FTC Seeking Public Comment on Proposed Guidelines for COPPA Compliance

At the recent ABA Roundtable on Social Media Law co-sponsored by our firm, one of the topics of discussion was the FTC's enforcement of the Children's Online Privacy Protection Act of 1998 ("COPPA"). As part of its ongoing efforts to protect children's privacy, the FTC has called for public comments on whether changes to technology warrant modifications to COPPA. According to the FTC's March 24, 2010 release, among the questions it is asking are:

  • What implications for COPPA enforcement are raised by mobile communications, interactive television, interactive gaming, or other similar interactive media.
  • For input on the use of automated systems - those that filter out any personally identifiable information prior to posting - to review children's Web submissions.
  • Whether operators have the ability to contact specific individuals using information collected from children online, such as persistent IP addresses, mobile geolocation data, or information collected in connection with behavioral advertising, and whether the Rule's definition of "personal information" should be expanded accordingly.
  • Whether there are additional technological methods to obtain verifiable parental consent that should be added to the COPPA Rule, and whether any of the methods currently included should be removed.
  • Whether parents are exercising their right under the Rule to review or delete personal information collected from their children, and what challenges operators face in authenticating parents.
  • Whether the Rule's process for FTC approval of self-regulatory guidelines - known as safe harbor programs - has enhanced compliance, and whether the criteria for FTC approval and oversight of the guidelines should be modified in any way.

Comments, which are due by June 30, 2010, may be submitted here.

Our firm's Internet Law practice group will continue to monitor these developments.

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