Today, the FTC sent more than ninety (90) “educational” letters to domestic and foreign businesses whose Web sites and online services (including mobile apps) appear to collect personal information from children that are 12 years old and under, in an attempt to help the businesses come into compliance with the amendments to the Children’s Online Privacy Protection (COPPA) Rule (the “Amendments”), going into effect on July 1. Our prior blogposts about the Amendments can be found here.
Copies of each one of the four (4) form letters may be found below:
- Letter to Domestic Companies That May Be Collecting Images or Sounds of Children
- Letter to Domestic Companies That May Be Collecting Persistent Identifiers from Children
- Letter to Foreign Companies That May Be Collecting Images or Sounds of Children
- Letter to Foreign Companies That May Be Collecting Persistent Identifiers from Children
The FTC also set up and maintains an e-mail hotline, where companies can ask FTC staff questions about how to comply with the Amendments.
The penalties for violating COPPA can be steep. In February 2012, social networking app Path agreed to pay $800,000 to settle FTC allegations that it wrongly collected personal information from children. And in October 2012, Artist Arena, the operator of fan websites for music stars such as Justin Bieber shelled out $1 million to settle FTC charges that it improperly collected personal information from children without parental consent.
Other prior COPPA penalties include $1 million paid by Sony BMG Music Entertainment in 2008, and $1 million by social networking Web site Xanga.com in 2006.