New Children’s Online Privacy Protection Rules Impose Heightened Compliance Standards on Website and Software Application Operators

Effective July 1, 2013, recently enacted Federal Trade Commission (FTC) regulations will impose greater obligations on website operators and online service providers under the Children's Online Privacy Protection Act (COPPA). This is the first revision to the COPPA regulations in over 10 years. COPPA already imposes certain parental consent requirements for website operators collecting personal information online from children under the age of 13. The new regulations extend compliance obligations to website owners and online software application providers, including mobile applications, not previously covered by COPPA and its existing regulations.

The new rules also broaden the definition of "personal information" from basics such as names and home addresses to include less obvious identifiers, such as certain screen names, particular geo-location information, audio-visual materials featuring a child's image or voice, and some uses of persistent identifiers, such as