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ARTICLE · 14 AUGUST 2025

The FTC's Updated COPPA Rule: Redefining Children's Digital Privacy Protection

Finnegan, Henderson, Farabow, Garrett & Dunner LLP
Finnegan, Henderson, Farabow, Garrett & Dunner LLP
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Enhanced Privacy Definitions: The amendments to COPPA now include biometric identifiers such as fingerprints, iris patterns, and voiceprints, alongside government-issued identifiers like passport numbers...

United StatesPrivacy
  1. Enhanced Privacy Definitions: The amendments to COPPA now include biometric identifiers such as fingerprints, iris patterns, and voiceprints, alongside government-issued identifiers like passport numbers, as "personal information," significantly widening the scope of data subject to regulation.
  2. Stricter Consent Requirements: Operators must now obtain separate parental consent specifically for third-party data disclosures unless those disclosures are integral to the service provided, promoting greater specificity and autonomy in consent practices.
  3. Comprehensive Security Measures: The revised rules mandate operators to establish written information security programs and require written assurances from third parties on maintaining appropriate safeguards, emphasizing stronger operational security and accountability.

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