CDT Files Comments with FTC in Response to COPPA Updates
On March 11, CDT filed comments with the Federal Trade Commission in response to their proposed updates to the Children’s Online Privacy Protection Act (COPPA) Rule. In the comments, we make several arguments:
- The COPPA Rule should include strong data minimization requirements;
- The FTC should strengthen and adopt its proposals around direct notice, verifiable parental consent mechanisms, and retention and deletion of children’s data;
- The definitions of biometric data and inferred data should be clarified, as should requirements around content personalization;
- The “child directed” determination should include, as proposed, a totality of the circumstances analysis, and the FTC should not require “constructive knowledge”; and
- The proposed educational exception to parental consent should be adopted with several important changes.
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