If your company has an online presence — or provides marketing or advertising services — you should be registered for the fifth webinar in our 2015 Wednesday Privacy Webinar series: The Long Reach of COPPA. Recall the recent FTC settlement agreement with Yelp — clearly a site not targeted at children — that cost… Continue Reading
Tag Archives: COPPA
Privacy Monday – May 18, 2015
Posted in Children, Cybersecurity, Data Breach, Data Breach Notification, Data Compliance & Security, Events and Webinars, Mobile Privacy, Online Advertising, Privacy Monday, Security, UncategorizedIt’s Monday morning — do you know your privacy/security status? Here are a few bits and bytes to start your week. SEC to Registered Investment Advisers and Broker-Dealers: It’s Your Turn to Pay Attention to Cybersecurity The Division of Investment Management of the Securities & Exchange Commission (SEC) has weighed in on cybersecurity of registered investment companies… Continue Reading
Privacy Monday – March 23, 2015: COPPA Refresh
Posted in Children, Privacy Monday, Privacy RegulationOn Friday, the FTC published updates to the COPPA FAQs, the Commission’s compliance guide for businesses and consumers, to address the applicability of COPPA and the Amended COPPA Rule to educational institutions and businesses that provide online services, including mobile apps, to educational institutions. Specifically, nearly a year after the last update to the “COPPA… Continue Reading
Time to Step Up Your COPPA Compliance
Posted in Children, Federal Trade Commission, Privacy RegulationAs we promised in our post on the Yelp and TinyCo Federal Trade Commission COPPA enforcement actions, the Mintz Privacy Team has prepared an extensive review and analysis of both actions, and a helpful guide to avoiding COPPA violations. Client Advisory is available here.
BREAKING NEWS: THE COPPA ENFORCEMENT ACTIONS ARE HERE!
Posted in Children, Data Compliance & Security, Federal Trade CommissionWritten by Julia Siripurapu, CIPP As we predicted in prior blog posts (here and here), the Federal Trade Commission has begun its vigorous enforcement of the Amended COPPA Rule. And one of the players is not a child-related site, so read on.
COPPA Update: FTC Provides More Flexibility on Obtaining Verifiable Parental Consent
Posted in Children, Privacy RegulationWritten by Julia Siripurapu, CIPP/US Some clarification and a bit more flexibility was forthcoming late last week from the Federal Trade Commission to help ease compliance with the “new” COPPA. In its recent update to three FAQs in Section H (Verifiable Parental Consent) of the COPPA FAQs , the FTC provided important information on the topic of… Continue Reading
FTC Updates COPPA FAQs to Address Education Space
Posted in Children, Privacy RegulationWritten by Julia Siripurapu, CIPP The FTC has just published updates to the COPPA FAQs, the Commission’s compliance guide for businesses and consumers, to address the applicability of COPPA and the Amended COPPA Rule to educational institutions and businesses that provide online services, including mobile apps, to educational institutions. The “COPPA and Schools” FAQs cover in… Continue Reading
Complaint from BBB Triggers HarperCollins COPPA-Compliance Measures
Posted in Children, Data Compliance & Security, Online AdvertisingWritten 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 RegulationWritten 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
COPPA: New Year, New Requests to FTC For Investigation of Violations
Posted in Children, Federal Trade Commission, Privacy RegulationWritten 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 CommissionWritten 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
FTC Votes 4-0 to Extend Public Comment Deadline on Two COPPA Proposals
Posted in Children, Federal Trade CommissionThe 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 CommissionWritten 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 CommissionWritten 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 RegulationWritten 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 RegulationTime 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 RegulationWritten 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
FTC on COPPA: No Delay
Posted in Children, Federal Trade Commission, Privacy RegulationThis 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 RegulationUPDATE — 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
Nickelodeon Target of Privacy Complaint; Final COPPA Amendments to be Released Tomorrow
Posted in Children, Privacy RegulationWritten 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
Privacy and Security Bits and Bytes
Posted in UncategorizedOur Friday feature is back! FTC Imposes Largest Civil Penalty Ever for Violation of Children’s Online Privacy Protection Act (COPPA) – Magic Kingdom Subsidiary Pays Up The Chairman of the Federal Trade Commission, Jon Leibowitz, said: It’s the law, it’s the right thing to do, and, as today’s settlement demonstrates, violating COPPA will not come… Continue Reading
EchoMetrix Settles FTC Complaint Over Disclosure of Children’s Information to Marketers
Posted in Online AdvertisingThe Federal Trade Commission (FTC) has reached a settlement with EchoMetrix over charges that it failed to inform parents that information it was collecting about their children would be disclosed to third-party marketers. The company’s website says that EchoMetrix is a publicly traded systems development company that “understands and interprets content on the digital web.”… Continue Reading
Maine Lawsuit Dismissed and Law “Likely Unconstitutional”
Posted in LegislationThe kerfuffle over the controversial Maine law slated to become effective this week that would have prohibited all marketing to minors has been dismissed. Yesterday, the District of Maine issued a Stipulated Order of Dismissal stating that there is a likelihood that the statute is “overbroad and violates the First Amendment.” Further (and perhaps more… Continue Reading
Maine AG – I Will Not Enforce New Marketing Law
Posted in LegislationIt looks as though Maine’s Attorney General will not enforce a controversial new state law that restricts marketing to minors, but has drawn a federal lawsuit because plaintiffs argued that the law swept too broadly. The Wall Street Journal today reports that a spokesperson for Maine AG Janet Mills said that Mills will not be… Continue Reading
