Steven B. Roosa is a Partner in our
New York office.
The Federal Trade Commission (FTC) has recently responded to
three applications seeking approval for new methods for obtaining
parental consent under the Children's Online Privacy Protection
Rule.
In November, the Commission denied an application seeking
approval to use "social-graph verification" to verify a
parent's identity; "social-graph verification"
attempts to verify the identity of a parent by relying on a
parent's "friends" on a social network to verify a
parent's identity. Then in December, the Commission
unanimously voted to approve using "knowledge-based
authentication" to obtain parental consent, which verifies the
parent's identity through asking a series of "challenge
questions" that only the parent is capable of answering. The
third response, from late February, provides further details on the
scope and operation of the approved "knowledge-based
authentication" method.
