According to recent media reports, Google is allegedly designing a Google account for children  under 13 which would permit children in this age group to officially create  their own Gmail account and to access a kid-friendly version of YouTube. Google currently prohibits children 12 and under from creating a Google account by implementing an age neutral verification mechanism in the account creation process and using cookies to ensure that children cannot bypass the age screen on a subsequent try. As reported by the Wall Street Journal, “now Google is trying to establish a new system that lets parents set up accounts for their kids, control how they use Google services and what information is collected about their offspring… Google wants to make the process easier and compliant with the rules.”

The reported initiative, which has not yet been confirmed by Google, is certainly very interesting and would clearly require the tech giant to comply with the Children’s Online Privacy Protection Act (“COPPA”) and its implementing rule (as amended, the “COPPA Rule”). It will be especially interesting to see how Google handles the advertising component of the service, which is a major piece of its business. In order to comply with COPPA, Google would have to engineer and design the new service based on the requirements of the COPPA Rule. PC Magazine reported in its story that “as part of the move, Google will also introduce a dashboard where parents can oversee their kids’ activities.” This seems like a step in the right direction for Google, but it will be a long journey! As we all know, the COPPA Rule goes far beyond giving parents the right and ability to monitor their children’s online activities and includes, among other requirements, complex, parental notice and verifiable consent requirements. You can link here for a copy of the Mintz Levin Guide to COPPA.

As the first company that would offer an online service specifically targeting children under 13, Google would certainly be in the spotlight and the new service would be closely monitored by the privacy community and the FTC. In fact, privacy advocacy groups, like the Center for Digital Democracy (CDD), have already voiced concern, as reported by the Wall Street Journal, that “Unless Google does this right it will threaten the privacy of millions of children and deny parents the ability to make meaningful decisions about who can collect information on their kids.” CDD’s executive director, Jeff Chester, informed the Wall Street Journal that the CDD shared its concerns with the Federal Trade Commission on Monday and that the organization is in the process of creating an action plan for monitoring how Google rolls out the service to children.  The Wall Street journal also reported that the FTC declined to comment on the matter, “saying the agency does not comment on specific companies’ plans.”

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