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Category Archives: Children

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Online Protection for Children: Delaware following California?

Posted in Children

Written by Julia Siripurapu, CIPP/US Delaware state representative Darryl Scott recently introduced the Child Online Protection Act (House Bill 261 or the “Bill”), to the state’s House of Representatives. If passed, the Bill would: (1) prohibit the online marketing and advertising of certain products and services to children under the age of 18 (“Minors”) as well… Continue Reading

Unauthorized Children’s In-App Purchases Round Two: Google Faces Class Action

Posted in Children, Class Action Litigation

Written by Julia Siripurapu, CIPP/US Just two months after Apple’s settlement with the FTC over lax parental controls over children’s in-app purchases (see our prior blog post), Google takes the spotlight with claims of unauthorized children’s in-app purchases in the Google Play Store! This time, it’s not an FTC action, but a class action. The… Continue Reading

Complaint from BBB Triggers HarperCollins COPPA-Compliance Measures

Posted in Children, Data Compliance & Security, Online Advertising

Written by Julia Siripurapu The Children’s Advertising Review Unit (CARU) announced (press release) that  it has recommended that HarperCollins Publishers Ltd. (the “Company”) modify its information collection practices on its Ruby Redfort child-directed website (the “Site”) to better protect the privacy of children under 13  (“Children”) and that the  Company has agreed to do so…. Continue Reading

FTC Approves Another COPPA Safe Harbor Program

Posted in Children, Federal Trade Commission, Privacy Regulation

Written by Julia Siripurapu The FTC has announced its unanimous approval for the kidSAFE Seal Program proposed by Samet Privacy, LLC under the “safe harbor” provision of the COPPA Rule (the “kidSAFE Seal Program”). The Commission’s decision comes after an extended public comment period due to the agency’s shutdown last year.  For more information regarding… Continue Reading

BREAKING NEWS: FTC Announces Major Settlement with Apple

Posted in Children, Federal Trade Commission

Written by Julia Siripurapu and Cynthia Larose Apple Agrees to Pay Consumers At Least $32.5 Million to Settle Complaint of Unfair Billing Related to Children’s In-App Charges FTC Chairwoman Edith Ramirez just announced (press conference) that Apple, Inc. (“Apple”) has agreed to provide consumers full refunds of at least  $32.5 Million Dollars to settle the… Continue Reading

COPPA: New Year, New Requests to FTC For Investigation of Violations

Posted in Children, Federal Trade Commission, Privacy Regulation

Written by Julia Siripurapu As we predicted in our prior blog post reviewing the key children’s privacy developments of the past year, 2014 is turning out to be the year of enforcement of children’s privacy regulations! The first two requests for investigation under the Amended COPPA Rule have been filed with the FTC by the Center… Continue Reading

COPPA: “Knowledge-Based Authentication” Method Approved by Federal Trade Commission

Posted in Children, Federal Trade Commission

Written by Julia Siripurapu The FTC has announced (press release) that it has unanimously approved the knowledge-based authentication method proposed by Imperium, LLC (“Imperium”) as a COPPA-compliant method of obtaining verifiable parental consent (“VPC”). Knowledge-based authentication has been used by entities in the financial services industry to authenticate users for several years. For more information… Continue Reading

On the Seventh Day of Privacy, the FTC Gave to Me….

Posted in Children, Federal Trade Commission, Privacy Regulation

Significant compliance obligations with children’s privacy rules!  Written by Julia Siripurapu, CIPP/US Last December, the FTC gave to us the long awaited (or maybe not so much by covered entities!) final amendments to the 14-year old Children’s Online Privacy Protection Act (COPPA) Rule (the “COPPA Rule,” and as amended, the “Amended COPPA Rule”). Published in… Continue Reading

On the Second Day of Privacy, California Gave to Me……

Posted in Children, Data Breach Notification, Data Compliance & Security, Legislation, Privacy Regulation

Well, the headlines don’t exactly work with the traditional tune, but blame the editor for that….. Written by Jake Romero, CIPP/US 2013 was a busy year for California.  We passed a budget with a surplus, let Kim and Kanye get engaged in one of our stadiums and panicked over possibly losing Sriracha sauce.  At the… Continue Reading

Privacy Monday – November 18, 2013

Posted in Children, Cybersecurity, Privacy Monday, US Supreme Court

The month of November is quickly slipping by – this is the time to be looking at the 2014 cybersecurity and data privacy goals and updates and planning ahead. Our selected bits and bytes for this Monday: FTC Denies AssertID, Inc.’s Application for Obtaining Verifiable Consent Under the COPPA Rule The FTC recently announced (press… Continue Reading

FTC Votes 4-0 to Extend Public Comment Deadline on Two COPPA Proposals

Posted in Children, Federal Trade Commission

The FTC has announced (press release) that, as a result of the recent shut down of the agency, the Commission has voted unanimously to extend the public comment periods for two recent proposals under the COPPA Rule. Specifically, the public comment period for the verifiable parental consent solution proposed by Imperium, LLC (“Imperium VPC Method”) scheduled… Continue Reading

FTC Seeks Public Comment on Proposed kidSAFE COPPA Safe Harbor Program

Posted in Children, Federal Trade Commission

Written by Julia Siripurapu, CIPP In a Federal Register notice to be published shortly, the FTC is seeking public comment on the kidSAFE Seal Program proposed by Samet Privacy, LLC under the “safe harbor” provision of the COPPA Rule. This provision enables industry groups or other interested entities to submit to the FTC for approval… Continue Reading

FTC Invites You to Comment on Another COPPA Verifiable Parental Consent Method

Posted in Children, Federal Trade Commission

Written by Julia Siripurapu The FTC has announced (press release) that it is seeking public comment on a second verifiable consent method proposed under the Voluntary Commission Approval Process provision of the COPPA Rule. The proponent is Imperium, LLC (“Imperium”), a Connecticut-based technology services company. The Federal Register notice inviting public comment will be published shortly…. Continue Reading

You Can Have a Say on a New Mechanism for Obtaining Verifiable Parental Consent under the COPPA Rule

Posted in Children, Federal Trade Commission, Privacy Regulation

Written by Julia Siripurapu, CIPP Yesterday, the FTC published a Federal Register notice requesting public comment on the first new method for obtaining verifiable parental consent submitted for FTC approval by AssertID, Inc under the Voluntary Commission Approval Process provision of the COPPA Rule. The FTC is particularly interested in receiving comments on the questions… Continue Reading

Amended COPPA Rule Compliance Deadline Approaching

Posted in Children, Data Compliance & Security, Federal Trade Commission, Mobile Privacy, Privacy Regulation

Time flies when it comes to compliance deadlines   As we have blogged here, the Amended COPPA Rule compliance deadline is approaching.   And if you haven’t addressed your compliance issues by Monday, you will be late. Effective July 1, 2013, regulations issued in the December 2012 amendment to the Children’s Online Privacy Protection Act (COPPA)… Continue Reading

The Great Disappearing Acts: California Considers Two Bills Addressing the Removal of Online Information of Minors

Posted in Children, Legislation, Privacy Regulation

Written by Jake Romero Do you ever find yourself worrying that, given the types of things minors deem appropriate to post on social networking Web sites like Facebook and Twitter, our country won’t be able to produce an electable candidate for president in 40 years?  If so, you’ll be glad to know that the California… Continue Reading

July 1 COPPA Compliance Deadline is Approaching

Posted in Children, Federal Trade Commission, Privacy Regulation

Written by Julia Siripurapu Today, the FTC sent more than ninety (90) “educational” letters to domestic and foreign businesses whose Web sites and online services (including mobile apps) appear to collect personal information from children that are 12 years old and under, in an attempt to help the businesses come into compliance with the amendments… Continue Reading

FTC on COPPA: No Delay

Posted in Children, Federal Trade Commission, Privacy Regulation

This afternoon, the Federal Trade Commission (FTC) unanimously rejected requests from industry organizations to delay the July 1 date for compliance with the amendments to the Children’s Online Privacy Protection Act (COPPA).    In its response letter, the Commission noted that the updated rule has been in the works for three years and the July… Continue Reading

War of Words Regarding Implementation of Amendments to COPPA – UPDATE

Posted in Children, Federal Trade Commission, Privacy Regulation

UPDATE — The Federal Trade Commission has published its promised COPPA FAQs here.      Volley #1 – Trade Associations to FTC:  Please Delay! The long-awaited amendments to the Children’s Online Privacy Protection Act (COPPA) have been the subject of much discussion and debate.  Last week, Federal Trade Commission (FTC) Chairwoman Edith Ramirez received letters… Continue Reading

Updated COPPA Rule – “Strong, Stronger and Yet Stronger” or Just More Confusion?

Posted in Children, Federal Trade Commission, Privacy Regulation

Written by Amy Malone After years of consideration and feedback the Federal Trade Commission released the final revision to the 14-year old Children’s Online Privacy Protection Act (COPPA) Rule.  The FTC began its review of the Rule back in April 2010 and we reported on the proposed amendments here.  The revised Rule, with only a few exceptions, essentially… Continue Reading

Nickelodeon Target of Privacy Complaint; Final COPPA Amendments to be Released Tomorrow

Posted in Children, Privacy Regulation

Written by Amy Malone The Center for Digital Democracy (CDD) filed a complaint yesterday asking the Federal Trade Commission (FTC)  to investigate violations of the Children’s Online Privacy Protection Act (COPPA) by Nickelodeon and mobile app-maker PlayFirst. The CDD alleges that the mobile game SpongeBob Diner Dash collects personal information about children, including full names,… Continue Reading

Cyberbullying

Posted in Children

My colleagues, Robert Delahunt, Jr. and Matthew Levitt, have authored an excellent advisory on cyberbullying that should be required reading for every parent. Cyberbullying – Talking to Your Children About Responsibility Using Social Networking and Electronic Communications

House Committee to Hold Hearing on FTC’s COPPA Revisions

Posted in Children, Data Compliance & Security, Privacy Regulation

The Federal Trade Commission has released its long anticipated proposed revisions to its rule implementing the Children’s Online Privacy Protection Act (“COPPA”).  COPPA governs (1) operators of websites and online services that are directed to children under the age of 13 and (2) operators of general audience websites or online services that have actual knowledge that… Continue Reading