COPPA-compliant Validation Method Approved by the FTC

Under recent amendments to the Children’s Online Privacy and Protection Act (COPPA), website operators who solicit information from minors under the age of 13 are required to obtain verifiable parental consent to receive such information. However, the FTC has left new method of verification of parental consent up to operators, subject to FTC approval. The FTC has recently approved the first method of verifying parental consent. The service, offered by Imperium, LLC, involves “knowledge-based authentication”. Under this system, a child signing up to a website or mobile application must enter the name and email address of their parent. The system then sends an email with a link for the parent to grant consent by providing their name, address, birthdate, and the last four digits of their Social Security number. The system verifies this information against consumer databases. If the system cannot reliably verify, as a second option it will send knowledge-based personal questions based on information from consumer databases (e.g. previous addresses, phone numbers, etc.). The FTC is also considering a similar verification process. Under this process, the parent again inputs their name, address, and last four digits of their SSN. Using this data, the system searches consumer databases to generate up to six random knowledge-based personal questions for the parent to answer. The parent must also provide a telephone number for the system to call to complete the verification process. Given the added, more rigorous step of telephone verification, it is expected that the FTC will also approve this process at the end of the public comment period. The FTC also rejected another proposed social network-based method for lack of reliability. It involved having accessing a parent’s social networks to ask their contacts to verify whether the person was indeed the parent of the child. However, the FTC did not reject the concept outright, citing the need for further studies to better establish the reliability of the system.

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