Archives: Children’s Privacy

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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

FTC Enters Into COPPA Settlement With Online Talent Search Company

On Monday, the Federal Trade Commission (FTC) entered into a settlement with Nevada-based Prime Sites, Inc., doing business as Explore Talent, related to charges that Explore Talent violated the Children’s Online Privacy Protection Act (COPPA).  Explore Talent, an online talent search company, will pay $235,000 in civil penalties. According to the FTC’s complaint, Explore Talent … 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The Article 29 Working Party (WP29) has published long-awaited draft guidance on transparency and consent under the General Data Protection Regulation (“GDPR”).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

U.S. Supreme Court Denies Cert In VPPA Case

Yesterday, the Supreme Court denied certiorari in In re Nickelodeon Consumer Privacy Litigation, a case addressing whether static digital identifiers like internet protocol (IP) addresses qualify as personally identifiable information (PII) under the Video Privacy Protection Act (VPPA).  As a result, the Third Circuit’s June 27, 2016 decision in the case—which held that IP addresses … 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

Children’s Website Modifies Privacy Practices in Response to CARU Inquiry

In an example of successful industry self-regulation, the website DorkDiaries.com revised its privacy practices for children’s data, following an inquiry from the Children’s Advertising Review Unit (CARU). CARU, the children’s arm of the advertising industry’s system of self-regulation, monitors advertising to children in all media.  As part of that effort, it examines websites and apps … 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

Microsoft and Other Leading K-12 School-Service Providers Pledge To Protect Student-Data Privacy

Yesterday, several big tech companies that offer educational and school services signed the “Student Privacy Pledge,” introduced by the Future of Privacy Forum (“FPF”) and The Software & Information Industry Association (“SIIA”) to safeguard student privacy as it relates to the collection, maintenance, and use of students’ personal information.  Among the fourteen education tech companies … Continue Reading

What the FTC’s Latest COPPA Settlements Mean for Mobile Apps

Making good on its warnings that mobile apps will be an enforcement priority under the revised Children’s Online Privacy Protection Act (“COPPA”) Rule, the FTC has announced two settlements with mobile app developers: TinyCo., the developer of several child-directed mobile apps, will pay $300,000 to settle charges that it violated COPPA by collecting children’s email addresses through its mobile app … Continue Reading

FTC Staff Updates COPPA FAQs on Verifiable Parental Consent Methods

The FTC staff has posted revisions to three Frequently Asked Questions (“FAQs”) related to obtaining verifiable parental consent under its COPPA Rule. For a comparison of the old and new FAQs, click here. Although the changes (which include a new FAQ H.16) may appear substantial, they mostly reaffirm the FTC’s longstanding position that the agency’s … Continue Reading

FTC Denies First Request For More Flexible Parental Consent Methods

The FTC has denied AssertID’s request to recognize a new method for obtaining verifiable parental consent for the online collection, use, and disclosure of personal information from children under 13.  The application was the first of its kind to be filed since the FTC added a voluntary parental consent approval process to its revised rule implementing … Continue Reading

CA Governor Signs Bill Providing Online Protections For Minors

Earlier this month, we blogged about the California Senate’s passage of the bill titled “Privacy Rights for California Minors in the Digital World”, which prohibits certain targeted advertising to California minors and requires that minors be allowed to delete materials they have posted online.  Yesterday, California Governor Jerry Brown signed the legislation, and it will … Continue Reading

CA Legislature Passes Bill Establishing Online Protections for Minors

Last Friday the California Senate unanimously passed legislation titled, “Privacy Rights for California Minors in the Digital World,” which prohibits certain types of marketing to minors (defined as a natural person under the age of 18 residing in California) and allows minors to delete materials they have posted online.  The bill, which already cleared the … Continue Reading

FTC Reminds Mobile App Developers To Comply With Revised Children’s Privacy Requirements By July 1

The Federal Trade Commission has sent letters to more than 90 different companies who develop mobile apps that the FTC claims may be directed to children.  The letters emphasize that the FTC has not evaluated the apps or the companies’ practices to determine if they comply with the current or revised COPPA Rule.  Instead, the letters remind these … Continue Reading
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