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No – nobody is really suggesting a block on kids. But the FTC is taking a fresh look at the Children’s Online Privacy Protection Rule and we couldn’t resist the title’s reference to 90s tweens’ favorite boy band, now parents themselves. For years we’ve been “Hangin’ Tough” about the need to protect kids’ personal information online, but it’s time for a “Step By Step” review of the COPPA Rule.

In place since 2000 and revised in 2013, the COPPA Rule requires certain sites and online services that collect personal information from kids under 13 to provide notice to parents and get verifiable parental consent. But time and technology change – Daddy, what is this thing Section 312.5(b)(1) calls a “facsimile”? – so it’s important that the Rule reflect the current state of play.

The FTC is asking for your feedback on all things COPPA – including whether the Rule should be retained or modified; how the definitions, notice and consent requirements, and safe harbor provision are holding up; and the impact of the 2013 revisions. In addition, we’ve posed some specific questions:

  • Has the Rule affected the availability of websites or online services directed to children?
  • Does the Rule correctly articulate the factors to consider in determining whether a site or online service is directed to kids, or should additional factors be considered? For example, should the Rule be amended to better address sites and services that may not include traditionally child-oriented activities, but have large numbers of users under 13?
  • Do technologies like interactive TV, interactive gaming, etc., have specific implications under COPPA?
  • Should there be an exception to the parental consent requirement for education technology in schools?
  • Should the Rule be modified to encourage general audience platforms to police child-directed content uploaded by third parties?

Once the Notice runs in the Federal Register, you’ll have 90 days to file a public comment.

As part of putting COPPA under the regulatory microscope, we’re also announcing The Future of the COPPA Rule: An FTC Workshop, scheduled for October 7, 2019. Mark your calendar and watch for updates on the event. Interested in participating as a panelist or have suggestions about agenda topics? Email us at by August 19, 2019.


August 22, 2019
Do this with the parent
James Russell
September 16, 2019
With search engine metadata such as the behaviors of searches and locations combined with machine learning, does it matter that direct consent is given when identity can be assumed by those means?
November 16, 2019
People who make animation memes cant exactly fit into either, parents dont mind personalized ads. They can get YT kids or YT premium, right? Isnt that why YT kids was made?! No, no coppa, you are tearing down the animation meme community.
November 20, 2019
After reviewing the new rules specifically as they apply to YouTube the standards are discriminant and vague. Anyone that used bring colors or makes mention of a cartoon or something that could in any way be connected to a child behavior is being removed from any opportunity to make the living as a content creator they once were able to be. I myself as a small time creator find challenges because I want my content to be visible but not in violation and its nearly impossible to not take a gamble. Please understand that the standards by which a fine can be issued need to be very clear guidelines that don't so braudly sweep YouTube many creators which a very wide variety of content that might wrongfully be found to be targeted toward children.
November 21, 2019
Coppa is not doing what it was intended to do. Going after YouTube creators that provide meaningful and responsible content are being penalized when coppa' s true intention was to stop online predators not kid friendly content.

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