As part of an ongoing effort to help businesses comply with the requirements of the updated Children’s Online Privacy Protection Rule, the Federal Trade Commission sent educational letters to more than 90 businesses that may be affected by the changes.
The letters went to companies both in the U.S. and abroad whose online services, including mobile applications, appear to collect personal information from children under 13 , as defined by the revised rule. While the letters do not reflect an official evaluation of the companies’ practices by the FTC, they are designed to help businesses come into compliance with the rule’s requirements when they go into effect July 1.
The FTC adopted final amendments to the COPPA Rule in December 2012. Under the revised rule, the definition of “personal information” has been expanded to include photos, videos and audio recordings of children, as well as persistent identifiers that can recognize users over time and across different web sites and online services. Persistent identifiers can range from online user names to cookies or mobile device ID numbers.
Companies whose apps collect, store or transmit this information, as well as other personal information previously covered by the rule like a child’s name or address, must get parents’ consent before collecting the information. In addition, companies must also ensure that any third party receiving the information can keep it secure and confidential, as well as abiding by new rules affecting how the information is stored and retained.
The rule applies not only to information collected by the apps themselves, but also to any information collected by third parties like advertising networks within the apps.
The FTC issued one letter to domestic companies that may be collecting images or sounds of children and another letter to domestic companies that may be collecting persistent identifiers from children. In addition, the agency issued similar versions of both letters to foreign companies whose content is directed to children in the U.S. [sound and image collection | persistent identifier collection].
The FTC recently issued updated frequently asked questions about the revised COPPA rule, and staff maintain an e-mail hotline, COPPAHotLine@ftc.gov, where companies can ask questions about how to comply with the revised rule.
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