As an aspiring independent developer, here are some things I’m going to do, after reading the latest revisions to the proposed COPPA rule, to keep my life simple.
- If I’m just releasing a straightforward educational app, I’m going to make sure that I’m in charge of the code and no services are integrated from a third party. If I include code from a third party, and that software happens to collect information that could identify a child, I might be liable (according to my personal interpretation of the legislation) and therefore subject to COPPA compliance.
- I’m going to continue to read COPPA legislation, first-hand, so I am aware of the policies (even if I don’t completely understand them because I’m an indie and don’t have access to in-house counsel) that drive the market I’m entering. If I have questions, concerns or comments, I will submit them directly to the FTC: https://ftcpublic.commentworks.com/ftc/2012copparulereview/.
- I’m going to encourage the talented developers around me to think entrepreneurially about the market opportunities present for 3rd party services well versed in COPPA and tailored to respecting children’s online privacy. HINT 1: What is the solution for verifiable parental consent for kids’ apps? HINT 2: Is there a company that specializes in analytics collection that respects the need to ONLY use that information to support internal operations and not as targeted marketing ammo, specifically for the under 13 market?