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. To see our previous blog post on the FAQs, please click here.
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
