By Mary Hildebrand and Jacqueline Klosek
Children’s Online Privacy a Growing Concern
Since the Children’s Online Privacy Protection Act (COPPA) entered into force, the Federal Trade Commission has commenced a number of enforcement actions against entities for collecting and/or using personal data from children in a manner that violates the requirements of COPPA. Recently, the FTC imposed the largest COPPA civil penalties to date, fining Mrs. Fields Cookies $100,000 and Hershey Foods $85,000.
In the case of Mrs. Fields, the FTC focused on claims that the company had collected personal information from children without having first obtained parental consent. Hershey, on the other hand, did obtain parental consent before it collected information from children. However, the FTC found that the company’s method of obtaining consent did not comply with the requirements of COPPA. These recent enforcement actions highlight the importance of ensuring that information collection