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The Future of the COPPA Rule: An FTC Workshop

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Event Description

The Â鶹´«Ã½ Trade Commission hosted a public workshop on October 7, 2019 to explore whether to update the Children’s Online Privacy Protection Rule.

The Future of the COPPA Rule: An FTC Workshop examined whether to update the COPPA Rule in light of evolving business practices in the online children’s marketplace, including the increased use of Internet of Things devices, social media, educational technology, and general audience platforms hosting third-party child-directed content. The COPPA Rule, which was enacted in 2000 and updated in 2013, requires certain Web site operators to obtain parental consent before collecting, using, or disclosing personal information from children under 13. Workshop topics included:

  • How the development of new technologies or business models, the evolving nature of privacy harms, and changes in the way parents and children use websites and online services, affect children’s privacy today;
  • How the Rule should address parental consent for education technology vendors that collect personal information consented to by schools, following on discussions that occurred during the FTC’s Student Privacy and Ed Tech workshop in December 2017;
  • Whether the Rule should include a specific exception to parental consent for audio files containing a child's voice that website operators collect and then promptly delete;
  • Whether the Rule should permit general audience platforms to rebut the presumption that all users of child-directed content are children, and if so, under what circumstances;
  • Whether the revisions to the Rule made in 2013 have worked as intended or require modification; and
  • Whether the Rule should be amended to better address websites and online services that do not include traditionally child-oriented activities, but that have large numbers of child users.

For a more detailed list of topics, see the .

The workshop was free and open to the public.

  • 8:30 am

    Registration

    9:00 am

    Introductory Remarks

    Jim Trilling
    Division of Privacy & Identity Protection, FTC

    9:05 am

    Opening Remarks

    Christine S. Wilson
    Commissioner, FTC

    9:15 am

    Presentation

    Dr. Jenny Radesky
    Developmental Behavioral Pediatrician & Assistant Professor of Pediatrics, University of Michigan Medical School

    “The Digital Playground: App Design, Data Collection, and Policy Implications”

    9:30 am

    Panel 1: State of the World in Children’s Privacy

    Panelists:
    Phyllis Marcus
    Partner, Hunton Andrews Kurth LLP
    Laura Moy
    Associate Professor & Associate Director, Center on Privacy & Technology, Georgetown University Law Center
    Jo Pedder
    Head of Regulatory Strategy, United Kingdom Information Commissioner’s Office
    Claire Quinn
    Vice President, Compliance, PRIVO
    Dr. Jenny Radesky
    Developmental Behavioral Pediatrician & Assistant Professor of Pediatrics, University of Michigan Medical School
    Janne Salminen
    Senior Legal Counsel, Rovio Entertainment Corporation

    Moderators:
    Peder Magee & Jim Trilling, Division of Privacy & Identity Protection, FTC

    10:50 am

    Break

    11:05 am

    Remarks

    Noah Joshua Phillips
    Commissioner, FTC

    11:15 am

    Panel 2: Scope of the COPPA Rule

    Panelists:
    Parry Aftab
    Executive Director, The Cybersafety Group
    Malik Ducard
    Vice President of Content Partnerships, YouTube
    James Dunstan
    General Counsel, TechFreedom
    Dona Fraser
    Vice President, Children’s Advertising Review Unit, BBB National Programs, Inc.
    Josh Golin
    Executive Director, Campaign for a Commercial-Free Childhood
    Don McGowan
    Chief Legal Officer & Business Affairs, The Pokémon Company International

    Moderators:
    Peder Magee & Maneesha Mithal, Division of Privacy & Identity Protection, FTC

    12:30 pm

    Lunch Break

    1:30 pm

    Presentation

    Morgan Reed
    President, ACT | The App Association

    “Developers and COPPA: Their Real-World Experience”

    1:45 pm

    Panel 3: Definitions, Exceptions, and Misconceptions

    Panelists:
    John E. Ahrens
    CEO, Veratad Technologies, LLC
    Ariel Fox Johnson
    Senior Counsel, Policy & Privacy, Common Sense Media
    Sheila A. Millar
    Partner, Keller & Heckman LLP
    Samantha Vargas Poppe
    Principal, Equity Matters, LLC
    Morgan Reed
    President, ACT | The App Association
    Steve Smith
    CIO, Cambridge Public Schools, Massachusetts
    Amelia Vance
    Senior Counsel & Director of Education Privacy, Future of Privacy Forum

    Moderators:
    Kristin Cohen & Jim Trilling, Division of Privacy & Identity Protection, FTC

    3:00 pm

    Break

    3:15 pm

    Presentation

    Jonathan Mayer
    Assistant Professor, Department of Computer Science & Woodrow Wilson School of Public & International Affairs, Princeton University

    “Technology Trends Since the Revised COPPA Rule”

    3:30 pm

    Panel 4: Uses and Misuses of Persistent Identifiers

    Panelists:
    James Cooper
    Associate Professor of Law & Director, Program on Economics & Privacy, Antonin Scalia Law School, George Mason University
    Harry Jho
    CEO & Co-Founder, Sockeye Media LLC; Co-Creator, Mother Goose Club
    Katharina Kopp
    Deputy Director & Director for Policy, Center for Digital Democracy
    Jonathan Mayer
    Assistant Professor, Department of Computer Science & Woodrow Wilson School of Public and International Affairs, Princeton University
    Kate O’Loughlin
    Chief Operating Officer of North America, SuperAwesome
    Julia Tama
    Partner, Venable LLP

    Moderators:
    Mark Eichorn, Division of Privacy & Identity Protection & Laura Hosken, Bureau of Economics, FTC

    4:45 pm

    Closing Remarks

    Maneesha Mithal
    Associate Director, Division of Privacy & Identity Protection, FTC

FTC Privacy Policy

Under the Freedom of Information Act (“FOIAâ€) or other laws, we may be required to disclose to outside organizations the information you provide when you pre-register for events that require registration. The Commission will consider all timely and responsive public comments, whether filed in paper or electronic form, and as a matter of discretion, we make every effort to remove home contact information for individuals from the public comments before posting them on the FTC website.

The FTC Act and other laws we administer permit the collection of your pre-registration contact information and the comments you file to consider and use in this proceeding as appropriate. For additional information, including routine uses permitted by the Privacy Act, see the Commission’s Privacy Act system for public records and comprehensive privacy policy.

This event will be open to the public and may be photographed, videotaped, webcast, or otherwise recorded.  By participating in this event, you are agreeing that your image — and anything you say or submit — may be posted indefinitely at ftc.gov or on one of the Commission's publicly available social media sites.

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