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Old May 16, 2013, 06:27 PM   #1
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FTC Begins Sending COPPA Letters to App Developers Ahead of July Rule Change




The U.S. Federal Trade Commission has begun sending educational letters to app developers to make them aware of upcoming changes to the Children's Online Privacy Protection Act (COPPA) that was updated back in December.

The two letters [PDF, PDF] inform developers that the restricted collection of personal information of kids 13-and-under has been expanded to include photographs and video and audio with a child's image, among other things. Previously, only identifying information such as the child's name, address, and telephone number was restricted.
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Please note that we have not yet evaluated your apps or your company's practices to determine if they comply with COPPA as it is now - or as it will be starting July 1, 2013. We are sending you this letter to both alert you to the upcoming COPPA Rule changes and to encourage you to review your apps, your policies, and your procedures for compliance.

The revised COPPA Rule requires all developers of apps that are directed to children under 13 - or that knowingly collect personal information from children under 13 - to post accurate privacy policies, provide notice, and obtain verifiable parental consent before collecting, using, or disclosing any "personal information" from children.
App 'platforms' like Apple's App Store and Google Play are explicitly exempted from the law and stores are not required to verify that apps are in compliance with the law; instead, it's up to individual developers to verify compliance.

Thanks Jules!

Article Link: FTC Begins Sending COPPA Letters to App Developers Ahead of July Rule Change
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Old May 16, 2013, 06:43 PM   #2
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App 'platforms' like Apple's App Store and Google Play are explicitly exempted from the law and stores are not required to verify that apps are in compliance with the law; instead, it's up to individual developers to verify compliance
The inefficiency, it burns!
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Old May 16, 2013, 08:26 PM   #3
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The inefficiency, it burns!
How so? If Apple were required to verify all apps for compliance with these new rules, it'd only slow the review process down further. Rather than making it so all developers have to deal with the implications of this law, only the developers making apps that actually pertain to the subject matter actually have to do anything about it.

Whether a law like this is actually necessary is another matter entirely... I'm always in favor of saying if a law mentions age, it's ageist bull.
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Old May 16, 2013, 08:34 PM   #4
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I also think it's the developer's responsibility. They are the ones making the initial app after all.
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Old May 17, 2013, 12:12 AM   #5
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In a way this sucks for developers because even if they rate an app 14+ kids can lie about it just like they can lie now about being 17 etc. Hell I know 8 year olds with their own apple id etc cause the parents lied about the kids age.

So developers are going to end up basically forced to remove all such sharing which will destroy apps like Instagram etc. or the law needs to be changed to either specify only apps targeted to kids.

Or perhaps what is needed is a restrictions feature where parents can turn off uploading of photos etc just like they can turn off IAP. All apps would be required to include it if they have such sharing features so that parents can turn those bits off.
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Old May 17, 2013, 12:49 AM   #6
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In a way this sucks for developers because even if they rate an app 14+ kids can lie about it just like they can lie now about being 17 etc. Hell I know 8 year olds with their own apple id etc cause the parents lied about the kids age.

So developers are going to end up basically forced to remove all such sharing which will destroy apps like Instagram etc. or the law needs to be changed to either specify only apps targeted to kids.

Or perhaps what is needed is a restrictions feature where parents can turn off uploading of photos etc just like they can turn off IAP. All apps would be required to include it if they have such sharing features so that parents can turn those bits off.
You should really read before you assume what this means. It's strictly for apps that are targeted at children. Has NOTHING to do with social networking.

There has been a policy since 1999 stating that if you make a website targeting to those 13 and under, it has to be very strict. Everything from the way signups work, to the display of any material that is submitted by the kid themselves.

I think there were other bits about marketing, but I can't remember. All I remember was that i was 10 when it went into effect and it was awful.

Yes, you can lie about your age, and yes, shortly when this went into effect, all my friends and I DID lie about our age in order to join forums and whatnot. But it wasn't like I was saying that I was 18, I just added three years to my birthday so I would be 13.

Webmasters can only go by the information they get from the user. If they sign up as being 13, they have to pass them as being 13. Now, if they start posting pictures and things that reveal that they are indeed much, much younger, it's then when the website owner has to take action and purge the account. And that's the whole thing here. If you're going to let anyone under 13 join your site, you have to hand it in THIS manner, or you can't let them participate.

A lot of developers have things like TrialPay, Tapjoy, and newsletter signups. They also have in-game chat, and all that. We're going to see a lot of that disappear in the educational games that are made for the younger crowd. It's not going to affect games like Angry Birds or social networks.
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Old May 17, 2013, 01:25 AM   #7
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Whether a law like this is actually necessary is another matter entirely... I'm always in favor of saying if a law mentions age, it's ageist bull.
Agreed. Big waste of everyone's time and money, and it hurts the small developers of all people (plus the taxpayers) to make sure that kids don't have their email addresses farmed.
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Old May 17, 2013, 09:16 AM   #8
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Or perhaps what is needed is a restrictions feature where parents can turn off uploading of photos etc just like they can turn off IAP. All apps would be required to include it if they have such sharing features so that parents can turn those bits off.
I would love to see far more parental restrictions. Android has basically zero, and many of iOS's are so broad as to be meaningless.
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Old May 17, 2013, 10:46 AM   #9
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Webmasters can only go by the information they get from the user. If they sign up as being 13, they have to pass them as being 13. Now, if they start posting pictures and things that reveal that they are indeed much, much younger, it's then when the website owner has to take action and purge the account. And that's the whole thing here. If you're going to let anyone under 13 join your site, you have to hand it in THIS manner, or you can't let them participate.
By unless some kid posts a photo marked something like 'my birthday party last night' and looks to be something like six years old, the sites aren't going to know if its a ten year old or a thirteen year old who looks younger or posted an old photo. And it doesn't really stop parents from filing complaints etc about how you were allowed to sign up in the first place. Forgot that you lied, these sites and games should have magically known the truth. Just like they should magically know that despite your parents giving you the password to their apple id you aren't supposedly to be using it for IAP etc.

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Agreed. Big waste of everyone's time and money, and it hurts the small developers of all people (plus the taxpayers) to make sure that kids don't have their email addresses farmed.
Especially since just as much farming is done by computer systems that randomly create usernames for the big services and then pull out the stuff that comes back with errors. NOT off websites etc
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