Tag Archives: COPPA

FTC Issues New but Narrow COPPA Guidance on Voice Recordings

Last week, the Federal Trade Commission (“FTC”) released a policy enforcement statement to provide additional guidance under the Children’s Online Privacy Protection Act (“COPPA”) for organizations that use audio voice recordings of children. This additional guidance builds on the FTC’s 2013 updates to COPPA that brought additional data types, such as photographs, videos and audio … Continue Reading

FTC Issues New COPPA Guidance Focusing on Ad Networks

It's now been almost a month since the revised COPPA Rule went into effect July 1, 2013. Earlier this year, the FTC issued new guidance on how to comply with the revised Rule. As part of its new guidance, the FTC provided a detailed set of FAQs. The FTC is planning to make additional revisions to their FAQs, with these revisions focusing on the obligations of ad networks. Specifically, the FTC explains in what circumstances an ad network is deemed to have "actual knowledge" that it has collected personal information from users of a child-directed site (see D.10, D.11, D.12), and the obligations of ad networks after they discover that they have been collecting personal information via a child-directed website (see K.2). The revised FAQs also relates traditional enforcement policy to the context of a button within an app that automatically opens an email program or social network. Providing the facility for a child to share personal information is just as problematic as if the operator was collecting that information itself. Thus, verifiable parental consent is required when permitting children to share content that may contain personal information - such as a painting combined with a field that allows for free expression.… Continue Reading

FTC Issues FAQs for Revised COPPA Rule

On April 25, 2013, the FTC provided additional guidance in relation to the revised COPPA Rule, set to go into effect July 1, with a detailed set of FAQs. Members of the business community have been calling for a delay in the effective date of the revised rules, so that businesses could have more time to get better acquainted with the rules.… Continue Reading

CARU’s 3rd Annual Children’s Advertising & Online Privacy Conference

CARU's West Coast Conference 2013 is scheduled for April 10 at the Beverly Hills Hilton, and once again promises to be a not-to-be-missed event. Confirmed speakers include Mamie Kresses, Federal Trade Commission; Katie Ratte, The Walt Disney Company; Jeannette Neumann, Mattel; Cynthia Nishimoto, Bandai; Stevan Levy, Kabillion; and Ryan Shadrick Wilson, The Partnership for a Healthier America. CARU believes if there is one conference to attend this year, this is the one, particularly in view of the impending COPPA modifications. CARU will devote a panel to the COPPA changes and will have detailed, lively discussions about the impact to the industry at-large. Indeed, rather than just a panel discussion, CARU hopes it will be more of a training session to prepare advertisers and website operators for the changes. Additionally, panelists will examine domestic and global challenges to self-regulation in the areas of social media, mobile marketing, sweepstakes, and food and beverage advertising.… Continue Reading

FTC to Mobile Industry: $800K… Can You Hear Me Now?

On February 1, the FTC announced its largest settlement to date with a mobile app developer – an $800,000 penalty – in conjunction with the release of guidance on mobile app best practices for app platforms, app developers, third parties and app trade associations.  The guidance document and the enforcement action together demonstrate the need … Continue Reading

Do you know where your children are?

Apparently, a lot of people want to know, according to the Federal Trade Commission Chairman Jon Leibowitz and Jeff Chester, Executive Director of the Center for Digital Democracy. To learn more why, read our Global Regulatory Enforcement Law Blog covering the latest complaint filed against a mobile game-maker for alleged COPPA violations.… Continue Reading

Child Obesity a Sign of Heart Disease

Children who are obese or who have high cholesterol also show early signs of heart disease, according to a new study. Results of the study were unveiled at a recent American Heart Association conference. The study, conducted by researchers from the University of Missouri Kansas City School of Medicine, has not yet been published. The … Continue Reading

CARU Refers Advertisers to FTC

The Children’s Advertising Review Unit (CARU) has referred two cases to the Federal Trade Commission because the advertisers failed to substantively respond to its inquiries. CARU examined advertising for the "Spray Racer," a toy vehicle powered by water and air that is compressed when a child manually pumps a holding tank. CARU questioned whether a … Continue Reading
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