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FTC Seeks Comments on COPPA

The Federal Trade Commission is requesting comments and input on the effectiveness of the 2013 amendments it made to the Children’s Online Privacy Protection Rule. Although the FTC typically reviews its rules every ten years, it is doing so early because of rapid changes in and children’s expanded use of technology. Part of the input it is seeking is whether the COPPA Rule should be updated again. Among the specific input the FTC has requested, it wants to know if companies and other interested parties believe that the Rule should be amended to include websites and online services that are not directed at children but have large numbers of child users.

The COPPA Rule first went into effect in 2000 to implement the Children’s Online Privacy Protection Act. COPPA requires online service providers that collect personal information from children under 13 to obtain parental consent before collecting information from children online. The 2013 Rule updates were aimed at keeping the law current with technological changes and children’s increased use of mobile devices and phones. Among other things, the 2013 amendments expanded the definition of personal information to include persistent identifiers such as cookies that track a child’s activity online, geolocation data, photos, videos and audio recordings.

A public workshop to discuss the progress of, and potential changes to the COPPA Rule, will be held by the FTC on October 7, 2019. Written comments must be filed with the FTC 90 days after the notice is published in the Federal Register, which is expected soon.

Putting it into Practice. Companies interested can submit comments to the FTC, or participate in the October 7, 2019 workshop.

Copyright © 2020, Sheppard Mullin Richter & Hampton LLP.


About this Author

Liisa Thomas, Sheppard Mullin Law Firm, Chicago, Cybersecurity Law Attorney

Liisa Thomas, a partner based in the firm’s Chicago and London offices, is Co-Chair of the Privacy and Cybersecurity Practice. Her clients rely on her ability to create clarity in a sea of confusing legal requirements and describe her as “extremely responsive, while providing thoughtful legal analysis combined with real world practical advice.” Liisa is the author of the definitive treatise on data breach, Thomas on Data Breach: A Practical Guide to Handling Worldwide Data Breach Notification, which has been described as “a no-nonsense roadmap for in-house and...


Rebecca Mackin is an attorney in the Intellectual Property Practice Group in the firm's Chicago office.