COPPA 2.0 FAQs: General Audience & Teen Sites

Sean Bryant

COPPA 2.0 compliance is here. Whether your site is ready or not, you need to be asking, enquiring, and doing whatever you can to come up to par with the current regulations. There is a laundry list of provision’s the FTC has put in to place and it’s time to comply.

Inversoft has provided a  shortened version of the ‘Business and Parents and Small Entity Compliance Guide’.

Please remember, this is merely a simplified reference. For more detailed information refer to the link at the bottom of this page.

COPPA Audience

1. Am I responsible if children lie about their age during the registration process on my general audience Web site?

The Rule does not require operators of a general audience to investigate the age of visitors to their site/service.

"However, operators will be held to have acquired 'actual knowledge' of having collected personal information from a child where, for example, they later learn of a child’s age or grade from a concerned parent who has learned that his child is participating on the site or service."

2. I have an online service that is intended for teenagers. How does COPPA affect me?

Although you may intend to operate a “teen service,” in reality, your site may attract a substantial number of children under 13, and thus may be considered to be a “Web site or online service directed to children” under the Rule.

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COPPA 2.0 FAQs: Geolocation Data

Sean Bryant

COPPA 2.0 compliance is here. Whether your site is ready or not, you need to be asking, enquiring, and doing whatever you can to come up to par with the current regulations. There is a laundry list of provision’s the FTC has put in to place and it’s time to comply.

Inversoft has provided a  shortened version of the ‘Business and Parents and Small Entity Compliance Guide’.

Please remember, this is merely a simplified reference. For more detailed information refer to the link at the bottom of this page.

 COPPA

Geolocation Data

 

1. I automatically collect geolocation information from users of my children’s app, but I do not use this information for anything. Am I responsible for notifying parents and getting their consent to such collection?

Yes.

2. What if I give my users a choice to turn off geolocation information? Do I still have to notify parents and get prior parental consent?

If there is any collection of geolocation information (no matter the options given to users) the operator is responsible notifying and obtaining consent from parents.

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COPPA 2.0 FAQs: Photos Videos & Audio Recordings

Sean Bryant

COPPA 2.0 compliance is here. Whether your site is ready or not, you need to be asking, enquiring, and doing whatever you can to come up to par with the current regulations. There is a laundry list of provision’s the FTC has put in to place and it's time to comply.

Inversoft has provided a  shortened version of the ‘Business and Parents and Small Entity Compliance Guide’.

Please remember, this is merely a simplified reference. For more detailed information refer to the link at the bottom of this page.

COPPA

Photos, Videos, and Audio Recordings

1. I run a moderated Web site that is directed to children and I prescreen all children’s submissions in order to delete personal information before postings go live. Do I have to get parental consent if I allow children to post photos of themselves but no other personal information?

Yes. Photos, videos, and audio recordings that contain a child’s image or voice are considered personal information.

Stipulations:

1) Prescreen children's submissions and delete any 'personal information'

2) Provide parents notice and obtain consent prior to children's  uploading content

2. I want to offer a child-directed app. The app would allow children to upload pictures of their favorite pets or places. I do not ask children to provide their email addresses or their names, or really any personal information for that matter. How does COPPA apply to me?

Under COPPA, 'personal information' applies to photos, videos, audio files, geolocation data (street name, city, town), including persistent identifiers collected via the children's upload.

To offer an app without parental consent the following steps must take place

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COPPA 2.0 FAQs: Websites & Online Services for Children

Sean Bryant

COPPA 2.0 compliance is here. Whether your site is ready or not, you need to be asking, enquiring, and doing whatever you can to come up to par with the current regulations. There is a laundry list of provision’s the FTC has put in to place, and on their behalf, have offered reasonable responses and substantial time to comply.

Inversoft has provided a  shortened version of the ‘Business and Parents and Small Entity Compliance Guide’.

Please remember, this is merely a simplified reference. For more detailed information refer to the link at the bottom of this page.

COPPA 2.0

Web Sites & Online Services Directed To Children

 

1. COPPA applies to Web sites or online services that are “directed to children.” What determines whether or not a Web site or online service is directed to children?

Specific factors include: subject matter, visual content, use of child orientated animation or activities, audio/music content, age of models, icons or celebrities that appeal to children, language or other characteristics that is child orientated...

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COPPA 2.0 FAQs: Privacy Policies & Parent Notifications

Sean Bryant

COPPA 2.0 compliance is just around the corner (July 1st, 2013). Whether your site is ready or not, you need to be asking, enquiring, and doing whatever you can to come up to par with the current regulations. There is a laundry list of provision’s the FTC has put in to place, and on their behalf, have offered reasonable responses and substantial time to comply.

Over the next week, Inversoft will supply shortened versions of the ‘Business and Parents and Small Entity Compliance Guide’.

Please remember, this is merely a simplified reference. For more detailed information refer to the link at the bottom of this page.

Privacy Policies

Privacy Policies & Direct Notices to Parents

 

1. My child-directed Web site does not collect any personal information. Do I still need to post a privacy policy online?

No.  However, the FTC recommends that all Web sites/services directed to children – post privacy policies online so visitors can easily learn about the operator’s information practices.

2. What information must I include in my online privacy policy?

While the original Rule required operators to provide extensive categories of information in their online privacy notices, the amended Rule now takes a shorter, more streamlined approach... Under the amended Rule, the online notice must state the following three categories of information:

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