FTC Reaffirms That IoT Devices Must Comply With COPPA

The Internet of Things ("IoT") can be thought of as a group of different devices that can communicate with each other, perhaps over a network such as the internet. We have written extensively about many of the privacy challenges that IoT devices can create. Recently, the Federal Trade Commission ("FTC") made clear that its Children's Online Privacy Protection Rule (the "COPPA Rule") would continue to be applicable to new business models, including "the growing list of connected devices that make up the Internet of Things. That includes connected toys and other products intended for children that collect personal information, like voice recordings or geolocation data."

To assist companies in complying with their COPPA obligations, the FTC has released an updated Six Step Compliance Plan. These steps are: