[co-author: Sidharth Sharma, Transportation Policy & Regulatory Specialist]

On November 1, 2019, a coalition of academics, officials and children’s activists in the United Kingdom issued a letter calling for the Federal Trade Commission (FTC or the “Commission”) to prioritize children’s privacy over the commercial interests of website operators as it considers updates to its regulations implementing the Children’s Online Privacy Protection Act (the “COPPA Rule”). The Commission is currently seeking public comments on potential updates to the COPPA Rule.

The letter urges the FTC to avoid amendments to the COPPA Rule that would lift restrictions on collecting data from viewers of child-directed content or expand parental consent exemptions for educational technology used in schools. The Children’s Commissioners of Wales, England, Scotland and Northern Ireland signed the letter alongside representatives from advocacy and academic organizations, including the London School of Economics and UNICEF U.K.

In the letter, the advocates note the “emerging consensus” in the U.K. and Europe that children need additional privacy protections online and suggest that the FTC build on this consensus through its updates to the COPPA Rule. These comments highlight the global impact of domestic law regarding data privacy. Although COPPA is a U.S. law, the European advocates stress that it affects children worldwide who access online services within its scope.

The FTC announced in July that it is seeking comments on potential updates to the COPPA Rule due to continued rapid changes in technology. Comments are due December 9, 2019.