Introduction

The Children’s Online Privacy Protection Act (COPPA) mandates that websites and online services directed to children under 13 must obtain verifiable parental consent before collecting personal information. Implementing effective procedures for parental consent verification is essential for compliance with COPPA and safeguarding children’s privacy. Below are three diverse examples of sample procedures for parental consent verification under COPPA.

Example 1: Email Confirmation Method

This procedure is suitable for online services that already have a communication channel with parents. It provides an easy way to confirm consent.

To implement this method, the website collects the parent’s email address during registration. After submission, an email is sent to that address containing a confirmation link. Upon clicking the link, the parent is directed to a consent form outlining the data collection practices. The consent is recorded upon the parent’s confirmation.

Notes:

• Ensure that the email used is verifiable and belongs to the parent.
• Include clear instructions and a deadline for responding to the email.
• Be mindful of response rates and consider follow-up reminders if necessary.

Example 2: Credit Card Verification Method

This method is more stringent and is useful for services requiring payment. It provides a secure way to verify parental consent.

In this procedure, parents are required to enter their credit card information on a secure payment page. The service provider performs a nominal charge (often less than $1) and uses it to confirm the parent’s identity. Upon completion, the parent is directed to a consent form explaining the data practices, where they can affirm their consent.

Notes:

• Use a secure payment processor to handle credit card information.
• Clearly communicate that the nominal charge will be refunded after verification.
• Ensure compliance with Payment Card Industry (PCI) standards.

Example 3: Video Conferencing Method

This approach can be engaging and is effective for services that offer interactive experiences. It allows for real-time communication for consent verification.

In this procedure, parents are invited to a scheduled video conferencing session where they can discuss the service and its data practices. During the session, the parent is asked to provide verbal consent while an employee documents the consent process. An official consent form is then sent via email for the parent to sign and return.

Notes:

• Choose a reliable video conferencing platform that ensures security and privacy.
• Prepare a script to guide the conversation and cover all necessary points.
• Follow up with the consent form promptly after the session to ensure compliance.