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Trying to keep pace with developments in internet-connected toys and other devices for children, the Federal Trade Commission (“FTC”) announced June 21, 2017 that it has updated its guidance, a “Six-Step Compliance Plan for Your Business,” for complying with the Children’s Online Privacy Protection Act (“COPPA”). COPPA is intended to help parents control what information is collected from young children. The FTC’s updated guidance, which is intended to help businesses understand when COPPA applies and how to comply with COPPA, includes the following changes:
Devices not directed to children, but used by children, like voice-activated personal assistants and wearables (like connected jackets, shoes, or pins), are creating COPPA issues for services that might not be considered directed to children. Even if your website, app, or connected device is not for children, it is prudent to know and assess COPPA’s potential requirements on your business.
If you have any questions about navigating COPPA or about this update, please contact Nadia Aram at 919.755.2119 or NAram@wcsr.com or the Womble Carlyle attorney with whom you normally work.