What’s Happening at the Coppa?

And by COPPA, I am not referring to the Barry Manilow “classic.”   I am instead, referring to the Children’s Online Privacy Protection Act, aka “COPPA.”   And there may be some big doings there.  

Here’s a piece about the Federal Trade Commission settling claims against two app developers who allegedly violated the federal statute.   What’s interesting to me (and potentially scary to app developers everywhere) is that the apps didn’t transmit any  personally identifiable information about any kids.  What they did do, however, was to allow ad networks to collect “persistent identifiers” to serve targeted ads.   

COPPA’s intent was to protect the privacy of children ages 13 and under.  And it prohibits companies from collecting personally identifiable information from children 13 and under without parental consent.  Most people consider personally identifiable information to include things like name, social security number, address and bank account information.  To restate it, PII is information that would allow someone to identify a person.  

The FTC, however, amended that definition, and now includes data used to create behavioral profiles, such as cookies and mobile device identifiers.  The two App developers – Retro Dreamer and LAI Systems – are the first to get caught in the considerably wider FTC net.   

If your company interacts in any way with kids, you would be well advised to look at what data you are collecting and what you’re doing with it.  I’d hate to be blogging about you in 2016!