FTC COPPA Rule Comment

In March 2024, TINA.org submitted a comment to the FTC regarding its proposed changes to the Children’s Online Privacy Protection Rule. In the intervening years since the FTC began its 2019 review of the Rule, TINA.org has encountered problematic issues with the use and marketing of Safe Harbor programs – issues that should be addressed in the FTC’s proposed amendments to the Rule. Specifically, while TINA.org’s comment expressed support for the Commission’s proposed amendments, it recommended additional revisions to Section 312.11 (the section pertaining to the FTC’s COPPA Safe Harbor program) in order to address when and how Safe Harbor program seals may be used in order to prevent misleading – and potentially harmful – representations regarding program approvals.

Click here to read TINA.org’s full comment.