In a recent decision, CARU found Snap Inc.’s (Snap) Snapchat app to be compliant with both the CARU Guidelines and the Children's Online Privacy Protection Act (COPPA).  “The company goes beyond minimal procedures to prevent under-age use” CARU stated. CARU determined that Snapchat is an app directed to a general audience, not intended for use by children. In reaching this conclusion, CARU considered that Snap’s Terms of Service clearly prohibit users under 13 years of age and makes no effort to market the app to children or provide them with an appealing user experience.  With that understanding, Snapchat is permitted under the Guidelines and Children’s Online Privacy Protection Act (“COPPA”) to age-gate and block children under 13 from using its services, which it does. CARU then examined whether Snapchat does so effectively. CARU observed that Snapchat utilizes age-gates and many safeguards to ensure that if children manage to breach the existing age-...

The Federal Trade Commission (FTC) typically reviews its rules every 10 years, but due to the rapid changes in technology, including the expanding use of education technology, the committee has decided to ask for comments on the amendments it made to the Children's Online Privacy Protection act (COPPA) in 2013. COPPA first went into effect in 2000 and its purpose is to protect children’s privacy by giving parents tools to control what information is collected from their children online. In addition to standard questions about the effectiveness of the COPPA Rule and whether it should be retained or modified, the FTC is seeking comment on all major provisions of the COPPA Rule, including its definitions, notice and parental consent requirements, exceptions to verifiable parental consent, and safe harbor provision.  The FTC will hold a public workshop on October 7, 2019 to examine the COPPA Rule. Some of the specific questions on which the FTC is seeking comment...