Deadline for Compliance with Updated COPPA Rules Draws Near

By:  Ronald G. London and Robert G. Scott, Jr. The July 1, 2013, deadline for complying with the Federal Trade Commission’s (FTC) updated regulations implementing its Children’s Online Privacy Protection Act (COPPA Rule) is around the corner, as discussed in our post here on the FTC’s denial of additional time and its revised “Frequently Asked Questions” to guide compliance efforts.  Our earlier advisory provides details on, e.g., the expansion of data collection activities covered by COPPA, including through persistent identifiers, new types of personal information whose collection will trigger the rule, clarification of how to obtain parental consent, refinements on what the Commission will deem to be a “child-directed” site covered by COPPA, and more.  The FTC’s COPPA Rule amendments are the first update to capture technological developments and evolving popular online practices – primarily social networking, smartphone Internet access, and the ability to use geolocation information – that arose after the law was enacted.