As we previously
reported, the Federal Trade Commission (FTC) adopted final
amendments to the Children's Online Privacy Protection Rule
(COPPA), effective on July 1, 2013, that serve to: (i) strengthen
online privacy protection for children under 13 years of age; and
(ii) ensure that parents are given an increased role in controlling
their children's online activities (including via mobile
apps).
The FTC recently updated the COPPA Frequently Asked Questions
("FAQs") section of its website to provide
additional guidance with respect to interpreting the COPPA
amendments. Specifically, the FTC made revisions to FAQ H.5,
which focuses on obtaining parental consent through the collection
of credit or debit card information; FAQ H.10, which focuses on
obtaining parental consent through third party apps; and FAQ H.16,
which focuses on third party platform liability for obtaining
verifiable parental consent for app developers.
