New technologies and the expansion of the Internet of Things have allowed children of this generation to experience seamless interactive technologies through microphones, GPS devices, speech recognition, sensors, cameras and other technological capabilities. These advancements create new markets for entertainment and education alike and, in the process, collect endless amounts of data from children–from their names and locations to their likes/dislikes and innermost thoughts.
The collection of data through this Internet of Toys is on the tongues of regulators and law enforcement, who are warning parents to be wary when purchasing internet-connected toys and other devices for children. These warnings also extend to connected toy makers, urging companies to comply with children’s privacy rules and signaling that focused enforcement is forthcoming.
Federal Trade Commission Makes Clear That Connected Toy Makers Must Comply with COPPA
On June 21 2017, the Federal Trade Commission (FTC) updated its guidance for companies required to comply with the Children’s Online Privacy and Protection Act (COPPA) to ensure those companies implement key protections with respect to Internet-connected toys and associated services. While the FTC’s Six Step Compliance Plan for COPPA compliance is not entirely new, there are a few key updates that reflect developments in the Internet of Toys marketplace.
- The Compliance Plan clarifies that any company providing “connected toys or other Internet of Things devices” are covered by COPPA, identifying a number of examples including “mobile apps that send or receive information online (like network-connected games, social networking apps or apps that deliver behaviorally-targeted ads); internet-enabled gaming platforms; plug-ins; advertising networks; internet-enabled location-based services”; and under certain conditions, voice-over internet protocol services.
- The revised Compliance Plan discusses two…