Five ways I’m going to address COPPA

by Moms With Apps on August 13, 2012

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.

  1. 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.
  2. 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/.
  3. I’m going to write a privacy policy that lets my customers know what I do and don’t do with data. If I use data from my customers, what do I use it for?
  4. I’m going to write a privacy policy, referenced or summarized in my app description, that lets my customers know the features I include in my app, so they are not surprised when they open the app and find that their child can do things like purchase additional modules, rate the app, or surf the internet – all from the menu screen.
  5. 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?
Creative, independent development of children’s online content is succeeding. I see it every time I look at the charts and find the app names of developers I know. Responsible progression with respect for children’s online privacy will help the marketplace thrive. Irresponsible progression will have issues. –Lorraine
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{ 1 comment… read it below or add one }

Charly August 14, 2012 at 12:05 am

Thank you, Lorraine. I was at a loss for / and about COPPA and you summarized this where I could understand it. I am a parent of two small children and not a developer yet I kept seeing “COPPA” and I could not find anything about it really. So I greatly appreciate the concise and informative information you have written in layman’s terms so-to-speak. Really appreciate it :-)

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