September 23, 2018

September 21, 2018

Subscribe to Latest Legal News and Analysis

September 20, 2018

Subscribe to Latest Legal News and Analysis

FTC Provides Insight into COPPA Deletion Requirements

The Federal Trade Commission recently posted a blog entry reminding companies about the deletion requirements under the Children’s Online Privacy Protection Act. Namely, that companies under the Act must give parents the right to review and delete their children’s information. In addition COPPA also requires companies to delete children’s personal information when the information is no longer necessary to fulfill the purpose for which it was originally requested. An example given is when a parent decides not to renew a subscription on behalf of their child. In that case, the company must delete the information even if the parent has not specifically requested deletion. The FTC recommends that companies make sure that their document retention policies take into account the stated purposes for which children’s personal information is collected, and under what circumstances the information will no longer be needed for those purposes. The FTC also recommends that companies ensure that they have secure deletion practices in place.

Putting it Into Practice: Companies who collect personal information about children under 13 should keep in mind that the FTC is thinking about COPPA’s deletion requirements. These include not only if a parent asks for deletion, but also when the information is no longer needed.

Copyright © 2018, Sheppard Mullin Richter & Hampton LLP.

TRENDING LEGAL ANALYSIS


About this Author

Shanna Pearce, Sheppard Mullin, San Diego, litigation, class action, intellectual property, IP, copyrights, false advertising, commercial litigation, lanham act, unfair competition
Associate

Ms. Pearce represents businesses in the areas of intellectual property and commercial litigation, from trademark and copyright matters to consumer class actions. She has represented Fortune 500 companies in complex actions involving allegations of copyright violation, breach of contract, fraud, and unfair business practices. She has also defended retailers and financial institutions in class actions alleging violations of statute and federal laws relating to false advertising, unfair competition, pricing practices, and lending disclosures. Ms. Pearce’s litigation...

858-720-7475