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Consumer Reports Comments on the Federal Trade Commission’s Proposed COPPA Rule Revisions

Consumer Reports submitted comments to the Federal Trade Commission in response to its Notice of Proposed Rulemaking on the Children’s Online Privacy Protection Act (COPPA) Rule. CR noted its support for the Commission on its proposed revisions in several areas, including:

  • Bifurcating the required collection of verifiable parental consent, such that parents would be able to consent to the collection of a child’s personal information but decline to consent to the disclosure of the child’s personal information to third parties;
  • Addition of biometric information as a category of personal information;
  • Clarification of existing restrictions that prevent businesses from collecting more personal information than is reasonably necessary for a child to participate in a game, offering of a prize, or another activity; and
  • Addition of data retention requirements by clarifying that operators must only retain personal information collected online from a child for only as long as is reasonably necessary to fulfill the specific purpose for which the information was collected and not for a secondary purpose.

CR also urged the Commission to further revise the Rule in several ways, including by:

  • Ensuring that screen or user names are be treated as “online contact information”;
  • Explicitly covering personal information inferred about a child; and
  • Narrowing exemptions operators can use to continue to serve targeted advertisements outside of the Rule’s consent provisions.

To learn more, please read our full letter.