If your station programs to children under the age of 13 or maintains a website or online presence directed to children under age 13, you should be aware of new rules proposed by the Federal Trade Commission (FTC) that will affect both the types of information you are allowed to collect from children and the manner in which it is collected. The proposed rules, summarized here, would modify the Children's Online Privacy Protection Rule enacted by the FTC to enforce the Children's Online Privacy Protection Act (COPPA) enacted by Congress in 2000.
COPPA requires parental consent whenever personal information is collected from children under the age of 13. The proposed rules, which would be the first changes made by the FTC since COPPA was enacted, are intended to reflect the recent popularity of social networking, smartphones and the availability of geolocation information.
Stations that have websites or apps dedicated to youth sports leagues or other children's activities could well be subject to these requirements, summarized in our recent Client Advisory available here. Interested parties may file comments on the new rules by November 28, 2011.