COPPA’s rules, however, have not kept pace with technological changes in digital advertising and mobile devices. The FTC is moving to catch up. Most websites, kid friendly or not, will need to make changes and work with vendors to ensure that their online marketing and data collection practices and policies are also compliant with COPPA’s changes.
Proposed changes include redefining “personal information” to include geolocation information and persistent tracking cookies used not for website functions but for behavioral advertising. Another change certain to be ‘Liked” by Facebook will be to redefine “collection” so that children may participate in interactive communities without parental consent, if all or virtually all of a child’s personal information is deleted before it is made public.
Other changes proposed include:
- requiring notices to parents be made in “real time”;
- stricter verification procedures for parental consents; and
- requiring website operators to ensure that service providers and third-parties, such as ad networks, who collect children’s personal information (PI) take reasonable procedures to: protect children’s PI; retain children’s PI only as is reasonably necessary; and dispose of children’s PI in a manner that ensures that the PI is properly deleted and prevent unauthorized access during disposal.
You have 30 days to comment and comply — better get busy!
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