Is Giving Parents a Voice in Their Child’s Privacy So Hard? Not Really…

US-FederalTradeCommission-SealThe Federal Trade Commission recently amended rules governing the Children’s Online Privacy Protection Act (“COPPA”) to afford greater protections to a child’s Personally Identifiable Information (PII) including:

  • Online contact information, including instant messaging user identifiers, voice-over internet protocol (VOIP) identifiers and video chat user identifiers;
  • A screen or username, where it functions in the same manner as online contact information;
  • Persistent identifiers, including an Internet Protocol (IP) address or mobile device IDs that can be used to recognize a user over time and across different websites or online services;
  • A photograph, video or audio file, where such file contains a child’s image or voice;
  • Geo-location information that’s sufficient to identify street name and the name of a city or town.
What is the big deal? If a site collects and, more importantly, shares a child’s PII with an ad network in a behavioral advertising context, then the website must get the consent of a verified parent. This is not email consent, where the website sends an email to a parent, and the parent clicks ‘okay’, (known by site operators as “email plus”). Under COPPA, when PII is collected from a child, the site must confirm that an adult or parent has given authorization, and can understand what is shared, and with whom it is shared. Weaknesses in ‘email plus’ prompted the FTC to implement measures to ensure that a parent is involved and has a voice.

What does that mean? Child-directed websites are scrambling. But they do not have to. There are a number of ways that they can implement what the new COPPA Rule defines as Prior Parental Verification (PPV). Some are easy to use, some not as easy. Some are online and some are offline. Some are instantaneous. To review a list of parental verification options offered by one of the FTC-approved COPPA Safe Harbor providers, click PPV.

Is it hard to do?  It sounds difficult, but to view an example of parental verification click this link for is a short video of the parental choices.

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