Protecting the privacy of our children is inherent to parenting. Parents guard against posting pictures of their children on social media or restrict the amount of time and the types of access they have on electronic devices. They may also set parental controls regarding content and try their best to protect their children. But what about the things we don’t see, like what data is being collected about our children’s online usage and what happens to that data? The Children’s Online Privacy Protection Act (COPPA), See 15 U.S.C. 6501 and regulations at 16 C.F.R. Part 312 et. seq. provide federal protections for children’s personal information as it relates to online services.

The Federal Trade Commission (FTC) investigates and brings enforcement actions when it believes companies are engaged in unfair or deceptive practices. Within the past year, the FTC brought an enforcement action involving internet connected toys with VTech Electronics [view related posts here and here].

In that case, the FTC alleged that VTech, a manufacturer of electronic learning products for children, collected their personal information without properly disclosing its data collection, use and disclosure practices; without providing direct notice to, and obtaining explicit consent from, parents; and without implementing appropriate procedures to safeguard such information.

In another case against Prime Sites, the FTC alleged that the online talent search firm failed to provide sufficient notice of the collection, use and disclosure of personal information from children, failed to obtain verifiable parental consent, and misrepresented its knowing collection of such information.

Both cases resulted in civil penalties, injunctive relief and ongoing compliance monitoring.

Recently, in a bi-partisan letter to Google regarding its subsidiary, YouTube, two members of Congress, Representative David N. Cicilline , (D. R.I.) and Representative Jeff Fortenberry, (R. Nebraska), fired off a list of nine questions to Google CEO Sundar Pichai that they want answered by October 17, 2018. A copy of the letter can be found here. The letter was prompted by the complaint filed by a coalition of twenty three advocacy groups alleging that YouTube has collected and shared the personally identifiable information of millions of children in violation of COPPA.

While the FTC is taking action on behalf of consumers, parents may wish to consider some additional measures to protect their children, including:

• taking the time to read the privacy policies of both Google https://policies.google.com/privacy and YouTube Kids. https://kids.youtube.com/t/privacynotice
• it may be helpful to search for helpful videos that guide parents through privacy policy navigation.
• be aware of what companies like Google and YouTube say they are doing with your children’s information and make privacy choices accordingly.
• access, modify, or delete children’s information by signing in to their Google account. https://families.google.com/familylink/privacy/child-policy/

Note that once a child turns 13, in general COPPA no longer applies, and Google allows children to manage their own account.

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