The Children’s Online Privacy Protection Act (“COPPA”) provides a safe harbor for companies that comply with FTC-approved self-regulatory guidelines.  Since COPPA’s enactment, the FTC has approved proposals submitted by CARU, ESRB, TRUSTe, and Privo, Inc.  

Aristotle, which operates the Integrity suite of age and identity verification services, recently filed an application with the FTC to become an FTC-approved safe harbor program.  In addition to the verifiable parental consent mechanisms that are contained in the FTC’s COPPA Rule, Aristotle proposes to allow companies to obtain parental consent using the following electronic methods:

  • verifying the last four digits of the parent’s Social Security Number;
  • verifying the parent’s driver license number;
  • sending an e-mail with an electronically signed parental consent form plus verification of an attached copy of a government-issued ID;
  • sending an e-mail with an attached copy of a physically signed parental consent form;
  • using a secure website plus verification of an uploaded copy of a government-issued ID;
  • using a secure website plus verification of an uploaded copy of a physically signed parental consent form;
  • transmission and verification of a photocopy of a government-issued ID through Multimedia Messaging Service (“MMS”);
  • transmission and verification of a photocopy of a physically signed parental consent form through MMS;
  • submission of the parent’s full name, birth date, and address, verified through the use of commercially available databases;
  • submission of the parent’s full name, birth date, and location, verified through the use of commercially available databases plus the mailing of a confirming postcard to the verified address; and
  • face-to-face real-time verification through Skype or other online telephony or videoconferencing technology.

The FTC is seeking comments on Aristotle’s application.  Comments are due by August 8, 2011.