COPPA 2.0 compliance is here. Whether your site is ready or not, you need to be asking, enquiring, and doing whatever you can to come up to par with the current regulations. There is a laundry list of provision’s the FTC has put in to place and it’s time to comply.
Inversoft has provided a shortened version of the ‘Business and Parents and Small Entity Compliance Guide’.
Please remember, this is merely a simplified reference. For more detailed information refer to the link at the bottom of this page.
Yes. Photos, videos, and audio recordings that contain a child’s image or voice are considered personal information.
1) Prescreen children’s submissions and delete any ‘personal information’
2) Provide parents notice and obtain consent prior to children’s uploading content
Under COPPA, ‘personal information’ applies to photos, videos, audio files, geolocation data (street name, city, town), including persistent identifiers collected via the children’s upload.
To offer an app without parental consent the following steps must take place
You do not need to notify parents/obtain consent if facial features are blurred prior to posting on the site; and all ‘personal information’ is removed from the file (geolocation).
COPPA is not triggered by an adult uploading photos of children on a general audience site or in the non-child directed portion of a mixed-audience Web site.
If the site/service is child directed the operator(s) must assume it is a child uploading the content and take the necessary steps to comply to the Rule:
No. You are not collecting personal information simply because your app interacts with personal information that is stored on the device and is never transmitted.
For more detailed information on Photos, Videos & Audio Recordings click here.