FTC Sends Educational Letters to Remind Companies and App Developers about COPPA Compliance Deadline

The Federal Trade Commission (“FTC”) is gearing up for the July 1, 2013 deadline for companies to implement necessary changes for compliance with the updates to the Children’s Online Privacy Protection Act (“COPPA”). The agency announced in a press release on May 17, 2013, that it has sent letters to more than 90 businesses to educate them about the updates which were adopted as final amendments to the rule in December 2012. Two types of letters were sent to both foreign and domestic businesses that appear to collect information, online or through mobile applications, from children under the age of 13. The first addressed those “that may be collecting images or sounds of children,” the second version was aimed at those “that may be collecting persistent identifiers from children.” The letters explain to recipients that under the new rules, personal information now includes “a photograph or video with a child’s image, or an audio file that has a child’s voice,” and “persistent identifiers, such as cookies, IP addresses and mobile device IDs, that can recognize users over time and across different websites or online services.” Both letters urge recipients to “review your apps, your policies, and your procedures for compliance" under COPPA and provides contact information for FTC Staff Attorneys to answer questions.