Partners Dana Rosenfeld
and Alysa Hutnik
authored the DataGuidance
article, "Children's Data (USA)." The article discusses the Federal Trade Commission ("FTC")'s recently issued final amendments to the Children's Online Privacy Protection Rule ("COPPA" or the "Rule'). The changes respond to substantial developments in consumer technology that have occurred over the past decade.
The FTC's amendments to the COPPA Rule impose significant new requirements on operators relating to who is subject to the Rule, parental notice and consent, the types of information that an operator can collect from children, and how such information must be protected. The authors advise such operators to carefully review the amended Rule to ensure that they understand their legal obligations and can implement any necessary changes to their business practices before the revised Rule goes into effect this upcoming July 2013.