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Expanded COPPA FAQs Come None Too Soon

By Lewis Barr | Posted on May 01, 2011

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There is little time to lose for companies whose websites and online services will be subject to the “new” COPPA Rule, which I wrote about in January. The new COPPA Rule is currently scheduled for July 1. While the FTC may respond positively to pending industry requests to push back the Rule’s effective date, it may not. So, the FTC’s expanded version of its COPPA FAQs released on April 25 is now a must read for those who will be affected by the new Rule.

Complying with COPPA: Frequently Asked Questions (A Guide for Business and Parents and Small Entity Compliance Guide) has 92 questions covering all things COPPA. Of special interest are the questions focused on the requirements of the new COPPA Rule, such as the following:

  • What should I do about information I collected from children prior to the effective date that was not considered personal under the original Rule but now is considered personal information under the amended Rule?
  • I already have a privacy policy for my children’s app. Do I have to change it to comply with the amended COPPA Rule?
  • I know that the amended Rule made some changes to the direct notice that must be sent to parents before I collect personal information from children. What are those changes?

A thorough review of the FAQs is recommended for a clearer understanding of the expanded COPPA requirements.

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About the author

Lewis Barr

Lewis Barr

General Counsel and VP, Privacy

Lewis manages Janrain's legal compliance and privacy functions as the company continues its international expansion. He brings more than 15 years of leadership in a wide range of legal and privacy-related matters for growing technology companies. Lewis also utilizes his diverse background as a litigator in private practice, federal appeals court staff attorney, and teacher. Prior to Janrain, Lewis was General Counsel and Secretary of Fios, Inc. and before that, he was General Counsel of New Edge Networks (now EarthLink Business). Lewis holds a Juris Doctor degree from the University of Missouri School of Law and a Bachelor's Degree from Georgetown University’s School of Foreign Service. He is also a Certified Information Privacy Professional (CIPP/US).

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