FTC Asks for Public Input on Company's Proposed COPPA Parental Consent Method

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Sept. 12 --The Federal Trade Commission Sept. 12 requested public comment on technology services company Imperium LLC's proposed parental consent method under the commission's Children's Online Privacy Protection Rule (78 Fed. Reg. 56183, 9/12/13).

In December 2012, the FTC released the final amendments to its rule implementing the Children's Online Privacy Protection Act, or COPPA Rule (11 PVLR 1833, 12/24/12). The COPPA Rule imposes parental notice and consent requirements on websites and online services collecting information from children younger than 13. The amendments took effect July 1.

Although the rule sets out several methods for obtaining verifiable parental consent, it also permits an “interested party” to request that the FTC review and approve a different consent method, the commission explained in its request for public comment.

Imperium, based in Westport, Conn., provides a service called ChildGuardOnlineTM that helps websites and mobile applications verify parental consent in compliance with the COPPA Rule.

According to the company's application, ChildGuardOnlineTM includes three components: a sign-up process during which the service sends an email to the parent and validates his or her identity; a verification process during which the website or mobile app pings the service to determine if the user has been approved; and a “portal” site that allows parents to review and withdraw permissions.

“We believe that ChildGuardOnline will address the FTC's requirements in a considerably more robust fashion than the standard use of 'email plus' and the other enumerated methods by themselves,” Imperium said.

The FTC said it is requesting comments on whether Imperium's proposed parental consent method: (1) is already covered by existing parental consent methods; (2) meets the COPPA Rule's parental consent requirements and “is reasonably calculated, in light of available technology, to ensure that the person providing consent is the child's parent”; and (3) poses any risks to consumers' personal information and whether any benefits outweigh those risks.

Comments are due by Oct. 9. The FTC said in a Sept. 9 statement that it has 120 days to review the proposal.

In August, the FTC asked for public input on a separate parental consent method proposed by privacy- and identity-verification technology company AssertID Inc. (12 PVLR 1439, 8/19/13).


The request for public comment is available at http://www.gpo.gov/fdsys/pkg/FR-2013-09-12/pdf/2013-22120.pdf.

Imperium's application is available at http://www.ftc.gov/os/2013/09/130909Imperiumapplication.pdf.