Are You COPPA Compliant?

Are You COPPA Compliant?

Talk to officials at any kids company with a Web site these days and you’re guaranteed to get an earful about their COPPA readiness. Company execs are spouting this unsolicited information with nervous frequency as the April 21 deadline to implement the Children’s Online Privacy Protection Act approaches.

There are plenty of companies out there that have work to do before their sites are kid safe, say Justin Osmer and Allison Pohn, director of communications and editorial director for FreeZone Network. FreeZone has been consulting with the FTC since COPPA’s inception in October 1998.

But most kids companies are making strides, says Loren Thompson, an attorney with the division of advertising practices for the FTC. And for those that aren’t ready, our panel of experts recommends the following approach:

* “Get ‘How to Comply with COPPA’ off the FTC Web site, and prioritize it,” Pohn says. “Go step by step technology-wise, and look at what needs to be written.”

* Use a checklist, Thompson says:

– Is your privacy policy on the Web site in the right place?

– Does the policy say what it needs to say?

– Are you ready and able to send notices to parents?

– Do you have procedures in place to field parent inquiries?

* Obtaining verifiable consent from parents for using or disclosing a child’s information will likely be the trickiest, costliest and most timeconsuming of COPPA’s provisions. Find out what types of information your site collects and how that info is used, then be sure you have procedures in place for sending notification and obtaining consent. Do you need to provide a hard copy consent form because you share kids’ information with other parties? Or can you rely on email because your chat rooms aren’t publicly available?

* “Don’t forget the end user,” Osmer says. “Privacy policies need to be approved by lawyers and meet FTC guidelines, but it can’t be so kids, parents and teachers can’t understand it.” “You can’t bring home to parents the dangers [of the Web] if a [parental notice] email isn’t written clearly,” Pohn says.

(FTC: Loren Thompson, 202/326-2000; FreeZone: Justin Osmer, Allison Pohn, 312/573-3800.)

Where To Go For Help

The FTC Web site and other online destinations offer a variety of links for anyone looking to bone up on COPPA:

http://www.ftc.gov/bcp/conline/pubs/buspubs/coppa.htm

This link breaks down the various provisions of COPPA with detailed, easy-to-read explanations. A great starting point for those looking to prioritize their efforts, and a good checklist for sites crossing t’s and dotting i’s.

http://www.ftc.gov/privacy/comments/caru2.htm

Comments from the Children’s Advertising Review Unit of the Council of Better Business Bureaus clarify CARU’s position on obtaining verifiable offline consent from parents of kids submitting information to a Web site. The link offers suggestions for defraying the higher costs of obtaining consent that have many companies worried.

http://www.cyberangels.org

CyberAngels, an online safety organization, has done extensive work with the FTC on COPPA. An “Ask Parry” feature on the Web site lets visitors submit online safety questions for Parry Aftab, CyberAngels executive director.

http://www.freezone.com/safety

FreeZone’s safety pages provide a look at one company’s expansive implementation of online regulations.

Offline, the Institute for International Research is offering “Online Privacy for Kids,” a one-day conference at the Helmsley Hotel in New York on April 18. (IIR: Erika Haggist, 212/661-3500 ext. 3026)

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