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CARU Submits Comments on the FTC COPPA Rule Review

The Federal Trade Commission (“FTC” or “Commission”) recently requested public comment on its implementation of the Children's Online Privacy Protection Act (“COPPA”), through the Children's Online Privacy Protection Rule (“COPPA Rule” or “the Rule”).

The Commission generally reviews its Rules every ten years to ensure that they have kept up with changes in the marketplace, technology, and business models. Although the Commission's last COPPA Rule review ended in 2013, the Commission decided to conduct its ten-year review early because of questions that have arisen about the Rule's application to the educational technology sector, to voice-enabled connected devices, and to general audience platforms that host third-party child-directed content. In addition to requesting comment on these issues, the Commission requested comments on the costs and benefits of the Rule, as well as on whether certain sections should be retained, eliminated, or modified.

After thoughtful co…
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CARU Director, Dona J. Fraser to Speak at The Future of the COPPA Rule: An FTC Workshop

The Federal Trade Commission recently announced its agenda for its upcoming workshop: The Future of the Children's Online Privacy Protection Act (COPPA). The Children's Advertising Review Unit (CARU) was thrilled that its director, Dona J. Fraser was invited to speak on a panel about such an important topic. CARU is not only a safe harbor provider under COPPA but it was the first program to be deemed with the honor.

The COPPA Workshop will be held on October 7, 2019, at the Constitution Center, 400 7th St., SW, Washington, DC, and is free and open to anyone who wishes to join.  For those not in the area, the event will be webcast live via the FTC's website.
About the COPPA Workshop The Future of the COPPA Rule: An FTC Workshop will examine 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 platform…

Keeping it Under Control, Parental Control

Parental controls come in a variety of forms from content filters to limiting screen time. At their essence, parental controls enable parents to limit what their children can and cannot do with their devices or online services. While these controls focus on restricting use and access, parental controls cannot monitor exactly what your children see and post online (although there are third party services that do). In a perfect world, parental controls would be a “set it and forget it” deal. However, this is not the case. While parental controls can be useful, they don't completely eliminate parental responsibility. For instance, they are not a substitute for teaching children how to appropriately use their digital devices nor are they a substitute for “verifiable parental consent” (required by COPPA for any online service collecting personal information of a child under 13) even if the child is browsing with parental controls on. 
It's always a good reminder to follow up with yo…

Google Agrees to a Record Fine to Settle COPPA Investigation over YouTube

Google will pay a fine of $170 million dollars to the Federal Trade Commission (FTC) and New York State Attorney General to settle an investigation into alleged violations of the federal Children’s Online Privacy Protection Act (COPPA) by its subsidiary video sharing platform, YouTube. The amount of the settlement is the largest fine imposed by the FTC in a case involving children’s privacy. The record was set just earlier this year for $5.7 million by the app TikTok for children’s privacy violations (originally referred to the FTC by CARU!). The investigation concerned the collection of children’s personal data and user activity without the consent of their parents. This information was then utilized to target ads at children. COPPA prohibits online service providers, such as YouTube, from collecting personal data from children under the age of 13 without their parent’s permission. 
In addition to the fine, as part of the settlement, YouTube agreed to take further action to protect ch…

Will YouTube End Targeted Ads on Videos Aimed at Children?

Bloomberg is reporting that YouTube may be finalizing plans to end "targeted" advertising on videos that children are likely to watch. The Federal Trade Commission (FTC) has been looking into whether YouTube violated the Children's Online Privacy Protection Act (COPPA). The agency is rumored to have reached a settlement with YouTube though terms of such a deal have yet to be released.

Currently YouTube offers two types of ads: one is contextual solely based on the content of the video and the other is targeted, based on a user's behavior. The latter requires companies to obtain parental consent before doing. According to reports from Bloomberg, the proposal would only end targeted ads. The rumored proposal, would not please complainants who submitted a complaint asking that YouTube move all content to a designated app for children. Joseph Simons, the FTC chairman asked in July if the groups would be satisfied if YouTube disabled ads on such videos. This rumored prop…

Shining a Light on Dark Patterns: Tips for How to Avoid Misleading Web and App Design Processes that Cause Consumer Confusion

As the internet has evolved, website designers and mobile app developers have learned to take user experience very seriously. Thanks to these improvements in design, unattractive pages full of flashing “click me” banners with neon text are a thing of the past. However, not all design innovation is beneficial for end users. A phenomenon known as “dark patterns”—user interface designs meant to manipulate users into performing certain actions—is becoming more common.
These tricks can be subtle or overt, and you’ve likely seen them. Dark patterns can range from a default setting during a website signup that also covertly signs you up for a newsletter (and even begs you to reconsider if you uncheck the box) to hiding shipping and tax costs until the last checkout page. Other dark patterns have likely led you to share more private information, buy items because of a possibly misleading suggestion that there were only a few left in stock, or spend money following the end of a “free” trial. Th…

Facebook in the News! Federal Trade Commission Announces “Rigorous New Standards” Regarding Privacy Following a $5 Billion Penalty

Facebook has been in the news A LOT in the past few days. We decided to round up everything going on to help our wonderful followers stay up to date! 
The biggest news of course is that in addition to a historic $5 billion settlement, the Federal Trade Commission (FTC) and Facebook have announced “sweeping new privacy restrictions” to be implemented on the social media platform.

The $5 billion penalty is the largest ever to be imposed against a company for violation of consumers’ privacy. This morning, this penalty was officially disclosed in addition to a stipulated order that can be read in its entirety here. Many have been critical that the FTC did not go far enough in imposing high enough of a penalty. However, at the press conference this morning, Commissioner Phillips made a point to note that "this penalty is to pay for the wrongs of this case, not to vindicate every consumer in the U.S."
After a year-long investigation, the Department of Justice filed a complaint alleg…