Comments to the Federal Trade Commission on Implementation of the Children’s Online Privacy Protection Act

ITIF has provided comments with the Federal Trade Commission regarding its implementation of the Children's Online Privacy Protection Act (COPPA). While the purpose of COPPA is to protect the privacy and safety of children under the age of 13 online, policymakers and advocates have moved the goal of COPPA from improving child safety into fundamentally limiting children’s access to many types of online services. Unfortunately, COPPA restrictions on the collection and use of information about children have discouraged the development of ad-support digital products and services for children. COPPA has no provisions to protect and encourage innovation across different business models, and the result has been a tightening of the regulations over time that have likely had a deleterious effect on the market for ad-supported children’s products and services.

ITIF recommends the FTC conduct a careful analysis of how COPPA can be structured for its original purpose while enabling an increase in the quality and quantity of websites and online services for children. The FTC should explore ways to lessen the regulatory burden of COPPA so as to foster more development of child-directed websites and online services using market-friendly methods. In particular, the FTC should recognize that the purpose of COPPA was not to limit advertising, and by limiting targeted ads with its strict rules on data collection, COPPA has made it difficult for companies to successfully monetize products and services directed at children.