On September 15, 2011, the Federal Trade Commission (“Commission”) released its long-awaited proposed amendments to its rule implementing the Children’s Online Privacy Protection Act (“COPPA Rule”). Comments are due by November 28, 2011.

The Commission proposes modifications to the COPPA Rule in three key areas:

-Expanding the definition of “Personal Information,” and therefore the scope of the COPPA Rule, including to the use of cookies for purposes other than support for the internal operations of the site or service;

-Altering the parental notice provisions and eliminating one commonly used consent mechanism; and

- Imposing new data security requirements, including pass-through obligations and limits on data retention.