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Financial Services Law Insights and Observations

FTC Releases Updates to COPPA Compliance Plan

Agency Rule-Making & Guidance FTC Privacy/Cyber Risk & Data Security Compliance Internet of Things

Agency Rule-Making & Guidance

On June 21, the FTC released updated guidance designed to assist businesses when complying with the Children’s Online Privacy Protection Rule (COPPA), which regulates what websites and online services are required to do to ensure the protection of children’s privacy and safety online. Specifically, the updates address the following issues: (i) the method by which companies monitor the collection of personal data as technology evolves in order to stay compliant; (ii) they ways COPPA impacts the “Internet of Things” as new “connected devices” continue to expand beyond websites and mobile apps; and (iii) new methods such as “ knowledge-based authentication questions and using facial recognition to get a match with a verified photo ID” to obtain parental consent. Additionally, the FTC revised its Six-Step Compliance Plan for Your Business to help companies determine whether they are covered by COPPA and how to comply with the rule.

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