Archives: Children’s Privacy

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French CNIL Publishes Recommendations for Protecting Minors Online

On June 9, 2021, the French Supervisory Authority (“CNIL”) published recommendations to help strengthen the protection of minors online (see here, in French).  These recommendations are the result of a survey and public consultation conducted by the CNIL in 2020, which focused on the digital practices of minors (see our blog post here).  The results … Continue Reading

Senators Markey and Cassidy Introduce Bill to Update the Children’s Online Privacy Protection Act

This week, Senators Ed Markey (D-Mass.) and Bill Cassidy (R-La.) introduced the Children and Teens’ Online Privacy Protection Act, which would update the Children’s Online Privacy Protection Act (COPPA).  COPPA is the comprehensive federal children’s privacy law enacted in 1998 that regulates the collection, use, and disclosure of personal information online from children under 13.… Continue Reading

French Supervisory Authority Publishes Results of Public Consultation on the Digital Rights of Minors

In January 2021, the French Supervisory Authority (“CNIL”) published a summary report of contributions it received in response to a public consultation and survey on the digital rights of minors launched in April 2020 (see the press release here and a summary report here, both in French).  Stakeholders who responded to the consultation included companies, … Continue Reading

European Commission Launches Consultation on Initiative to Fight Child Sexual Abuse

On February 11, 2021, the European Commission launched a public consultation on its initiative to fight child sexual abuse online (the “Initiative”), which aims to impose obligations on online service providers to detect child sexual abuse online and to report it to public authorities. The consultation is part of the data collection activities announced in … Continue Reading

Irish DPC publishes draft Fundamentals for a Child-Oriented Approach to Data Processing

On December 18, 2020, the Irish Data Protection Commission (“DPC”) published its draft Fundamentals for a Child-Oriented Approach to Data Processing (the “Fundamentals”). The Fundamentals introduce child-specific data protection principles and measures, which are designed to protect children against data processing risks when they access services, both online and off-line. The DPC notes that all … Continue Reading

California District Court Tosses Kids’ Data Collection Suit, Finds COPPA Preempts State Law

Judge Freeman of the U.S. District Court for the Northern District of California dismissed a class action against Google and several YouTube channel owners alleging various violations under California state law.  Plaintiffs alleged Defendants infringed their children’s privacy and consumer rights by collecting personal information and delivering targeted advertisements while they viewed child-directed YouTube videos.  … Continue Reading

Federal Trade Commission Updates, Streamlines COPPA FAQs

The FTC recently updated Complying with COPPA: Frequently Asked Questions, the set of FAQs meant to provide informal guidance for complying with the Children’s Online Privacy Protection Act and the Commission-issued COPPA Rule.  In an accompanying blog post, the FTC staff emphasized that the revisions to the FAQs “don’t raise new policy issues” and that … Continue Reading

European Commission Proposes Interim Regulation to Combat Child Sexual Abuse Online

On 10 September 2020, the European Commission proposed an interim regulation designed to enable online communications service providers to combat child sexual abuse online. Once in force, this regulation will provide a legal basis for providers to voluntarily scan communications or traffic data on their services for the limited purpose of detecting child sexual abuse … Continue Reading

New Bill Seeks to Impose Design Restrictions on Kids’ Online Content and Marketing

On March 5, Senators Ed Markey (D-MA) and Richard Blumenthal (D-CT) introduced the Kids Internet Design and Safety (KIDS) Act.  The bill, which covers online platforms directed to children and teenagers under 16 years old, aims to curb the time spent by these minors on such platforms and could dramatically affect advertising and influencer content … Continue Reading

Kids’ Privacy Bill Allowing for Private Suits Introduced in House

On January 30, House Rep. Kathy Castor (D-FL) introduced the Protecting the Information of our Vulnerable Children and Youth (“PRIVCY”) Act, a bill that promises to be a significant overhaul of the Children’s Online Privacy Protection Act (“COPPA”). Currently, COPPA applies only to personal information collected from children under 13 years old.  The PRIVCY Act … Continue Reading

FTC Reaches Settlement with Developer of Tracking Apps

On October 22, 2019, the Federal Trade Commission reached a proposed settlement with the developer of three so-called “stalking” apps that enabled purchasers of the app to secretly monitor the mobile devices on which they were installed.  Developer Retina-X Studios, LLC and its owner James N. Johns marketed the three apps—MobileSpy, PhoneSheriff, and TeenShield—as a … Continue Reading

FTC and New York Attorney General Reach $170 Million Settlement Against Google and YouTube for Alleged Children’s Privacy Violations

Yesterday, the Federal Trade Commission (“FTC”) and the New York Attorney General’s office (“NYAG”) settled allegations against Google LLC and its subsidiary YouTube, LLC claiming violations of the Children’s Online Privacy Protection Act and its implementing rule (together, “COPPA”).  The settlement requires Google and YouTube to pay $136 million to the FTC and $34 million … Continue Reading

CAC Releases Draft Regulation on the Protection of Children’s Personal Information Online

On May 31, 2019, the Cyberspace Administration of China (“CAC”) released the draft Regulation on the Protection of Children’s Personal Information Online (“Draft Regulation”) for public comment. (An official Chinese version is available here and an unofficial English translation of the Draft Regulation is available here.) The comment period ends on June 30, 2019. As mentioned … Continue Reading

ICO issues draft code of practice on designing online services for children

Earlier this month, the UK’s Information Commissioner’s Office published a draft code of practice (“Code”) on designing online services for children. The Code  is now open for public consultation until May 31, 2019. The Code sets out 16 standards of “age appropriate design” with which online service providers should comply when designing online services (such … Continue Reading

EU Regulators Provide Guidance on Notice and Consent under GDPR

The Article 29 Working Party (WP29) has published long-awaited draft guidance on transparency and consent under the General Data Protection Regulation (“GDPR”).  We are continuing to analyze the lengthy guidance documents, but wanted to highlight some immediate reactions and aspects of the guidance that we think will be of interest to clients and other readers … Continue Reading

FTC and Department of Education Announce Joint Workshop on FERPA and COPPA Compliance for Ed Tech

Earlier this week, the Federal Trade Commission and Department of Education announced plans to hold a joint workshop on the application of the Children’s Online Privacy Protection Act (“COPPA”) and the Family Educational Rights and Privacy Act (“FERPA”) to educational technology products and services in the K-12 school environment.  In advance of the workshop, the … Continue Reading

FTC Staff Publish COPPA Guidance for Businesses

The FTC staff published today a “Six-Step Compliance Plan” for businesses to comply with the Children’s Online Privacy Protection Act (COPPA). The guidance, which provides a useful framework for businesses, states explicitly that COPPA applies to connected toys and other devices that collect personal information from children over the Internet.  The FTC’s 2013 revisions to the COPPA Rule greatly expanded … Continue Reading

China Issues Draft Regulations on Protecting Minors in Cyberspace

China’s top internet regulator, the Cyberspace Administration of China (“CAC”), continues to show interest in setting more stringent rules governing the protection of minors in the context of online activities and data privacy. Immediately prior to the October holiday, CAC released for public comment new draft regulations aimed at protecting minors on the Internet, the … Continue Reading

FTC Approves New “Selfie” Verifiable Parental Consent Mechanism Under COPPA 

Under the Children’s Online Privacy Protection Act (COPPA), operators of certain websites, mobile applications, and other online services must provide parents notice and obtain verifiable parental consent before collecting, using, or disclosing personal information from children under the age of 13 online.  The FTC has approved a new facial-recognition based method to comply with COPPA, … Continue Reading

Regulators in the U.S. and U.K. Monitoring Mobile Apps and Websites Directed at Children

By Megan L. Rodgers What information is being collected by mobile apps and websites directed at kids? With whom is that information shared? What notice is provided to parents? Regulators in the U.S. and abroad continue to focus on these issues. The FTC recently released a follow-up report on privacy notices in mobile apps directed … Continue Reading

FTC Seeks Public Comment on New Proposal for Parental Verification Method Under COPPA Rule

By Ani Gevorkian The FTC has issued a request for public comment regarding Riyo’s application to recognize a new proposed verifiable parental consent method under the FTC’s Children’s Online Privacy Protection Act Rule.  The Rule, which implements the Children’s Online Privacy Protection Act (COPPA), requires certain website operators, mobile applications, and other online services to … Continue Reading

FTC Warns Foreign Mobile-App Developer To Comply With COPPA

In late December 2014, the FTC staff sent China-based mobile app developer BabyBus a letter warning the company that several of its apps may violate the FTC’s Children’s Online Privacy Protection Act (COPPA) Rule. Staff alleged that the apps are marketed for young children and “use cartoon characters to teach children letters, counting, shapes, music, … Continue Reading

FTC Denies AgeCheq Parental Consent Application But Trumpets General Support for COPPA Common Consent Mechanisms

The Federal Trade Commission (“FTC”) recently reiterated its support for the use of “common consent” mechanisms that permit multiple operators to use a single system for providing notices and obtaining verifiable consent under the Children’s Online Privacy Protection Act (“COPPA”). COPPA generally requires operators of websites or online services that are directed to children under … Continue Reading
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