FTC Extends Deadline for COPPA Comments from Nov. 28 to Dec. 23

Back in September, we extensively summarized the FTC’s announcement of the proposed revisions, which contemplate several major changes to the existing COPPA regime including:

• clarifying that the COPPA Rule applies not only to websites, but also to other technologies that can be considered “online services,” such as mobile apps, network-connected games, and some text messages; 

• a more expansive definition of “personal information” to include IP addresses, customer numbers held in cookies, device identifiers, the linking of information across websites, and geolocation information – all of which may impact companies’ behavioral advertising activities;

• streamlining and clarifying the notices that operators must provide to parents about their information collection practices;

• changing the existing parental consent mechanism by removing the popular “email plus” verification method and adding several new methods;

• enhancing security provisions and requiring operators to ensure that third-party service providers to whom an operator discloses a child’s personal information have reasonable privacy and security procedures in place; and

• changing the existing COPPA enforcement program to require “safe harbor programs” to exercise more oversight.

The previous deadline for the submission of comments was November 28.

Authored by Bret Cohen