Urgent Action Requested Regarding Call for Public Comments on
Children’s Online Privacy Protection Rule
TIA Member Input Needed No Later Than Monday, June
As previously reported to TIA members, the Federal Trade Commission
has issued a call for public comments on its implementation
of the Children’s Online Privacy Protection
Act (COPPA) through the Children’s Online Privacy
Protection Rule. Public input is solicited on the costs and
benefits of the Rule, as well as on whether it, or certain sections,
should be retained, eliminated or modified. Comments are due to
the FTC by June 30, 2010.
The Toy Industry Association (TIA), under the joint leadership of its
Responsible Marketing to Children Subcommittee and the Federal
Government Affairs Committee, along with the assistance of outside
counsel, will submit written comments on behalf of the toy
Given the tight timeline, development of the proposed comments is
currently underway. However, all TIA members are invited
to provide TIA
staff with input on their respective:
- level of satisfaction with the current Rule;
- concerns or proposed revisions to the current Rule;
- possible responses to FTC questions in 75 Federal Register 17089, April 5, 2010; and
- input on any other aspects of COPPA compliance or enforcement.
Toy industry stakeholder input is due to TIA as soon as possible but
no later than Monday, June 21st.
The review and proposed revision of the COPPA Rule was the subject of
a full-day roundtable held in Washington D.C. on June 2. As
discussed, consideration of an update has been prompted by rapidly
changing technology such as the increased use of smartphones and other
devices to access websites and online services, as well as new methods
for collecting and using information online.
The COPPA Rule was enacted in April 2000 and requires Web site
operators to obtain parental consent before collecting, using, or
disclosing personal information from children under 13. It also requires
that the operators keep the information they collect from children
secure, and prohibits them from requiring children to turn over any more
personal information than is reasonably necessary to participate in
activities on their Web sites.