Page 11 - SMRH Eye on Privacy 2019 Year in Review Brochure

stock of what you collect and how you use it. Over the coming months you will also want to look at how you might handle rights requests, and take the CCPA into account for your 2019 and 2020 budgeting. This graphic can help you communicate the importance of CCPA to internal stakeholders.
TIP: As we enter 2019, now is the perfect time to look forward to 2020 and get ready for the upcoming California privacy law.
CHILDREN’S PRIVACY
FTC Seeks Comments on COPPA Rule
Posted on July 26, 2019
The Federal Trade Commission is requesting comments and input on the effectiveness of the 2013 amendments it made to the Children’s Online Privacy Protection Rule. Although the FTC typically reviews its rules every ten years, it is doing so early because of rapid changes in and children’s expanded use of technology. Part of the input it is seeking is whether the COPPA Rule should be updated again. Among the specific input the FTC has requested, it wants to know if companies and other interested parties believe that the Rule should be amended to include websites and online services that are not directed at children but have large numbers of child users.
The COPPA Rule first went into effect in 2000 to implement the Children’s Online Privacy Protection Act. COPPA requires online service providers that collect personal information from children under 13 to obtain parental consent before collecting information from children online. The 2013 Rule updates were aimed at keeping the law current with technological changes and children’s increased use of mobile devices and phones. Among other things, the 2013 amendments expanded the definition of personal information to include persistent identifiers such as cookies that track a child’s activity online, geolocation data, photos, videos and audio recordings.
A public workshop to discuss the progress of, and potential changes to the COPPA Rule, will be held by the FTC on October 7, 2019. Written comments must be filed with the FTC 90 days after the notice is published in the Federal Register, which is expected soon.
PUTTING IT INTO PRACTICE: Companies interested can submit comments to the FTC, or participate in the October 7, 2019 workshop.
CARU Takes Action Against Two Mobile Apps
Posted on June 19, 2019
Two mobile apps directed at children were recently subject to action by the Children’s Advertising Review Unit. The first, “My Talking Tom,” is a virtual pet game for children operated by Outfit7 Limited. One issue was the display of Outfit7’s privacy policy. Under the Children’s Online Privacy Protection Act, privacy policies must be understandable, and contain no unrelated material. The app’s policy, however, contained advertisements for other games, and animated balloons that obstructed the user’s view. Accordingly, CARU found that the distracting content violated COPPA. Outfit7 prudently removed the content, and CARU took no further action on the issue.
Eye on Privacy 2019 Year in Review 10