Urgent Action Requested Regarding Call for Public Comments on Children’s Online Privacy Protection Rule

TIA Member Input Needed No Later Than Monday, June 21st

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 industry.  

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.