FTC Issues Update on COPPA

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Last week, the Federal Trade Commission (FTC) issued a six-step compliance plan to assist businesses with compliance with the Children’s Online Privacy Protection Act (COPPA). It provides clarity on who is covered by and must comply with COPPA and how companies can get parental consent. It also outlines a six-step compliance plan.

New companies that may be covered by COPPA include any company that is providing connected toys or other internet of things (IoT) devices (like Echo and Alexa). It also provides guidance that gives companies two new options for obtaining parental consent—asking knowledge-based authentication questions and utilizing facial recognition technology to compare a picture of a driver’s license or other photo ID submitted by the parent with a second photo from the parent. Obviously, before submitting to either, parents should read the privacy policy of the company to find out what they are doing with those photos and the use of facial recognition technology.

The new guidance can be accessed here.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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