COPPA

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As connected devices become ubiquitous, it comes as no surprise that interactive toys that connect to the internet are more popular than ever. At the same time, regulators have taken note of the privacy and security concerns raised by lawmakers and privacy advocates about the proliferation of smart toys that collect personal information from kids. Recent guidance issued by both the Federal Trade Commission (FTC) and the Federal Bureau of Investigation (FBI) suggests that the agencies may be taking a closer look at the rapidly expanding connected toy market, a small part of the largely unregulated “Internet of Things.”
Continue Reading Hello, Dolly: What You Need to Know About Connected Smart Toys and Privacy

ThinkstockPhotos-178868654The Federal Trade Commission (FTC) recently approved a new method for website operators and mobile application developers (“operators”) to obtain parental consent to collect personal information from children.1 Under this new method, which is the first to use biometric identifiers to verify that a parent is providing consent for a child, the FTC will permit operators to use facial recognition technology to compare an image of the person providing consent with an image of verified photo identification, such as a drivers’ license or passport. If the two images match, the user is verified and can provide consent for the child to use the website or mobile application.
Continue Reading FTC Approves Facial Recognition as Method of Obtaining Parental Consent to Collect Children’s Information

On December 17, 2015, the Federal Trade Commission (FTC) announced its first Children’s Online Privacy Protection Act (COPPA) enforcement actions challenging the use of persistent identifiers to engage in targeted advertising to children. The FTC…
Continue Reading WSGR Alert: FTC Brings First Enforcement Actions Against Kids Apps Using Persistent Identifiers for Targeted Advertising

The Children’s Online Privacy Protection Act (COPPA) prohibits companies from collecting personal information from children under the age of 13 without first providing notice to parents and obtaining their verifiable consent. The Federal Trade Commission’s (FTC) recent settlements with Yelp and TinyCo serve as a reminder to mobile app developers that the failure to consider COPPA when developing and testing mobile apps can have serious consequences.
Continue Reading COPPA Looms Large for Mobile Apps

In January 2014, President Barack Obama charged his counselor John Podesta with looking at: (a) how the challenges inherent in big data are being confronted in the public and private sectors; (b) whether the United States can forge international norms on how to manage big data; and (c) how the United States can continue to promote the free flow of information in ways that are consistent with both privacy and security. Two reports were published on May 1, 2014, in response to this charge, one focusing on policy and big data (the “Policy Report”)1 and the other complementing and informing the Policy Report with a focus on technology and big data (the “Technology Report”).2

Both reports acknowledge that there is no one definition of “big data.” However, big data is differentiated from data historically collected about individuals (“small data”3) in two ways: big data’s quantity and variety, as well as the scale of analysis that can be applied to big data. And, while both reports view big data as potentially providing great benefits to the economy, society, and individuals, they also identified its potential to cause significant harm.
Continue Reading President’s Counselor Makes Recommendations on Privacy and Other Values in Big Data Age