Children’s privacy remains front and center for the FTC. Through a new enforcement policy statement (Statement) issued at the end of February, the agency is promoting wider adoption of robust age-verification technologies pursuant to its authority to enforce the Children’s Online Privacy Protection Act Rule (COPPA). The Statement clarified that the FTC will not take enforcement action under COPPA against operators of general audience or mixed audience sites and services that collect, use or disclose PI for the sole purpose of determining a user’s age — provided they comply with certain conditions. This article discusses the Statement, with practical insights on how it will affect organizations and best practices from Nelson Mullins and Blank Rome. See our three-part series “Children’s Privacy Grows Up”: Examining New Laws That Now Protect Older Teens (Jan. 15, 2025), FTC Amends COPPA Rule and Targets Data Sharing (Jan. 29, 2025), and “Seven Compliance Areas for Protecting Teens” (Feb. 12, 2025).
