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ARTICLE · 28 APRIL 2014

FTC Updates COPPA FAQs To Address Education Space

Mintz, Levin, Cohn, Ferris, Glovsky and Popeo, P.C.
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The FTC has just published updates to the COPPA FAQs to address the applicability of COPPA and the Amended COPPA Rule.

United StatesPrivacy

The FTC has just published updates to the COPPA FAQs, the Commission's compliance guide for businesses and consumers, to address the applicability of COPPA and the Amended COPPA Rule to educational institutions and businesses that provide online services, including mobile apps, to educational institutions.

The "COPPA and Schools" FAQs cover in detail the key topic of consent in the school setting and provide compliance guidance for covered entities. Specifically, these new FAQs make it clear that:

  • An educational institution may consent, as a parent's agent, to a website or mobile app's collection, use or disclosure of personal information from the institution's students, but only in the educational context which is limited to collection of personal information from students for the use and benefit of the school and for no other commercial purpose. The operator's method for obtaining consent from an educational institution must be reasonably calculated, in light

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