The Children’s Online Privacy Protection Act (COPPA), enforced by the Federal Trade Commission (FTC), has governed how websites, mobile applications, and online services collect personal information from children under 13 since April 2000. By requiring clear notice, verifiable parental consent, data minimization, and robust security safeguards, COPPA empowers parents to make informed decisions about their children’s online privacy and compels operators to prioritize children’s safety.
COPPA applies to any commercial operator of a website, mobile app, or online service that is either “child-directed” or has actual knowledge it is collecting personal information from children under 13. This includes social networks, educational tools used in classrooms, gaming platforms aimed at kids, and advertising networks targeting child audiences. Exemptions cover purely informational sites with no data collection, general‐audience services without child targeting, and internal corporate tools inaccessible to the public.
Verifiable Parental Consent
Before collecting any personal information from a child, operators must obtain verifiable parental consent (VPC). This process ensures that parents understand and authorize exactly what data is collected and how it will be used. To implement VPC effectively:
- Design a clear consent form that outlines the types of information collected—such as name, contact details, geolocation, photos, and browsing behavior—and explains the service’s data practices.
- Use reliable verification methods, including credit‐card or debit‐card checks, government‐issued ID scans, certified digital signatures, or knowledge‐based authentication.
- Log and timestamp every consent granted, maintaining secure records to demonstrate compliance during audits or investigations.
Notice and Transparency
Operators must provide a conspicuous privacy policy that appears before any collection of personal information. The policy should explain:
- Which categories of data are collected (for example, identifiers, demographic data, usage logs).
- All purposes for which the data will be used or disclosed, including marketing, analytics, or sharing with third parties.
- Parents’ rights to review, correct, delete, or refuse further collection of their child’s information.
- Data retention practices and security safeguards in place.
Best practice: Place a direct link to the FTC’s children’s privacy guidance within your policy and include a brief FAQ section addressing common parental concerns.
Data Minimization and Retention
Under COPPA, only data reasonably necessary for the core functionality of the service may be collected. To enforce data minimization:
- Conduct a comprehensive audit of all data collection points to identify and eliminate non-essential fields, cookies, or tracking pixels that harvest children’s information.
- Implement automated deletion schedules that erase children’s data once it is no longer needed—for example, after account closure or after 30 days of inactivity.
- Prohibit sharing or selling children’s data to third parties unless explicitly authorized by the parent.
Parental Access, Review, and Deletion
COPPA grants parents the right to access and delete their child’s personal information at any time. To facilitate these rights:
- Offer a user-friendly online portal or clearly advertised email process where parents can submit review or deletion requests.
- Send automated confirmation notices once requests are fulfilled, documenting the action taken.
- Maintain an audit trail of all parental requests and the corresponding system updates for compliance reporting.
Security Safeguards
Reasonable security measures must protect children’s data against unauthorized access, accidental loss, or unlawful disclosure. Key steps include:
- Encrypting data both in transit (using TLS/SSL) and at rest (with AES-256 or equivalent standards).
- Enforcing role-based access controls so that only staff with a legitimate need can view or handle children’s information.
- Conducting regular vulnerability scans and penetration tests, and promptly patching identified weaknesses.
- Establishing an incident response plan that includes notification procedures for parents and regulators in the event of a breach.
Employee and Vendor Training
COPPA compliance is a cross-functional responsibility:
- Develop mandatory training modules for product, legal, marketing, and IT teams that cover COPPA’s requirements, the company’s specific policies, and incident escalation protocols.
- Require all third-party vendors and service providers handling children’s data to sign updated data-processing agreements that reflect COPPA obligations.
- Conduct annual refresher courses and tabletop exercises to reinforce best practices and maintain organizational awareness.
Ongoing Monitoring and Audit
Sustainable compliance demands continuous oversight:
- Perform quarterly internal audits of data collection, consent records, security controls, and parental request logs.
- Engage external legal counsel or specialized auditors annually to validate your privacy practices against the latest FTC guidance and enforcement trends.
- Update your privacy policy and technical safeguards promptly whenever new features, third-party integrations, or regulatory changes occur.
COPPA vs SCOPE Act
Adhering to COPPA requires a holistic blend of clear policies, technical safeguards, and organizational vigilance. By implementing verifiable parental consent workflows, transparent notices, data minimization strategies, secure data handling, and robust training programs—and by continuously auditing these measures—online service providers can protect children’s privacy, build parental trust, and avoid costly enforcement actions. Continuous improvement and adaptability to evolving technologies and regulations remain essential to maintaining a child-safe digital environment.