COPPA Compliance: Handling Children's Data Requests

Introduction

The Children’s Online Privacy Protection Act (COPPA) is a crucial regulation that protects the privacy of children under the age of 13. It requires that websites and online services obtain parental consent before collecting personal information from children. Understanding how to handle children’s data requests in accordance with COPPA is essential for compliance and building trust with your users. Below are three diverse, practical examples that illustrate effective approaches to managing these requests.

Example 1: Parental Verification Process

In this example, an educational app for children receives a data request from a parent wishing to access the personal information collected about their child. The app must ensure that the request comes from the actual parent or guardian.

To comply with COPPA, the app implements a multi-step verification process that includes:

• Email Confirmation: The parent submits a request through a dedicated email address. The app sends a confirmation link to the email address associated with the child’s account, which must be clicked to verify ownership.
• Identity Verification Questions: Upon clicking the link, the parent is prompted to answer specific questions that only a parent would know, such as the child’s birth date or the last transaction made in the app.
• Response Time: Once verified, the app provides the parent with the requested information within 45 days, as stipulated by COPPA.

Notes: This example emphasizes the importance of verifying parental identity before disclosing any personal data. Variations may include using third-party verification services for additional security.

Example 2: Data Deletion Request

This scenario involves a gaming website where a parent requests that their child’s data be deleted. The website must comply with COPPA by ensuring the process is clear and straightforward.

The gaming website handles the request as follows:

• Request Submission: Parents can submit a data deletion request through a dedicated form on the website. The form includes fields for the parent’s name, email, and the child’s account information.
• Confirmation of Identity: After submission, the website sends a confirmation email to the parent, requiring them to confirm their intent to delete the data by clicking a link.
• Data Deletion Process: Upon confirmation, the website processes the deletion request within 30 days, removing all personal information associated with the child’s account.

Notes: This process helps ensure compliance with COPPA while also maintaining transparency with parents. Websites may also want to provide information about the consequences of data deletion, such as loss of access to the child’s game progress.

Example 3: Updating Personal Information

In this case, a mobile app for children receives a request from a parent to update their child’s personal information, such as changing the email address associated with the account.

The app implements the following steps to handle this request:

• Request Submission: Parents are instructed to submit a request through the app’s help center, detailing the changes they wish to make.
• Verification Procedure: The app sends a verification email to the original email address on file, asking the parent to confirm their identity before any changes are made.
• Implementation of Changes: Once verified, the app updates the child’s personal information within 14 days and sends a confirmation email to the parent, summarizing the changes made.

Notes: This example highlights the importance of maintaining accurate records while ensuring parental consent is obtained before making changes to a child’s information. Variations may include implementing additional security measures, like two-factor authentication, for sensitive updates.

By following these examples of how to handle children’s data requests in accordance with COPPA, organizations can ensure compliance and foster a safe online environment for children.