Steven Roosa is a Partner in the
New York office
On April 22, the Federal Trade Commission (FTC) updated its
"Frequently Asked Questions" (FAQ) website to provide
additional information on how operators can collect students'
personal information—in compliance with the Children's
Online Privacy Protection Act (COPPA) — when consent is
obtained in the educational setting from entities or individuals
other than the child's parents.
In general, COPPA forbids online services from collecting data
on children under 13 without verified parental consent. A
previous post on this blog discussing approved methods for
obtaining verified parental consent under COPPA is available
here.
This general prohibition, however, has generated significant
uncertainty in the educational context.1 In a blog post
announcing the updates, FTC senior attorney Lesley Fair wrote:
"[E]ducators, administrators, and parents have been asking an
important question: How do the protections of
