Just in time for Christmas, the Federal Trade Commission
("FTC") unveiled its long-anticipated update to the
Children's Online Privacy Protection Rule ("COPPA Rule"). The COPPA Rule, which
has been in place since 1999, imposes a variety of privacy
requirements on "operators" of websites and online
services that are "directed to children" under 13 or have
actual knowledge that they are collecting "personal
information" from children. Among other requirements,
such operators must provide notice of their practices and obtain
verifiable parental consent before collecting, using, or disclosing
personal information from children.
Beginning on July 1, 2013, the COPPA Rule will impose new duties
on operators that already fall under COPPA, while also extending
the scope of the Rule to reach additional operators that previously
fell outside the Rule. Sites and services that may be
affected by these changes will want to reassess their practices in
light of this significant