Dealing with COPPA: Compliance, the lies and the future.

I don’t know about you but I am strug­gling with the Children’s Online Pri­vacy Pro­tec­tion Act (COPPA).

As we look to use dif­fer­ent online tools in the class­room we eval­u­ate them on the service(s) they pro­vide, whether they meet our edu­ca­tional goals, and what is involved in the man­age­ment and admin­is­tra­tion of the tool or service.

All of this is thrown a mess if the site’s account cre­ation process involves the col­lec­tion of per­sonal infor­ma­tion… enter COPPA compliance.

COPPA was enacted in 1998 the law requires that the Fed­eral Trade Com­mis­sion issue and enforce a rule con­cern­ing children’s online pri­vacy, which the com­mis­sion did in 1999. On April 21, 2000 the Children’s Online Pri­vacy Pro­tec­tion Rule became effective.


After read­ing the FAQ issued by the FTC one can still be left con­fused by what you actu­ally need to do as site oper­a­tor or as a school want­ing to use a site that may or may not be COPPA compliant.

In short, the Rule requires any web site that col­lects per­sonal infor­ma­tion to com­ply with six things:

  1. Post a clear and com­pre­hen­sive pri­vacy pol­icy on their web­site describ­ing their infor­ma­tion prac­tices for children’s per­sonal information;
  2. Pro­vide direct notice to par­ents and obtain ver­i­fi­able parental con­sent, with lim­ited excep­tions, before col­lect­ing per­sonal infor­ma­tion from children;
  3. Give par­ents the choice of con­sent­ing to the operator’s col­lec­tion and inter­nal use of a child’s infor­ma­tion, but pro­hibit­ing the oper­a­tor from dis­clos­ing that infor­ma­tion to third parties;
  4. Pro­vide par­ents access to their child’s per­sonal infor­ma­tion to review and/or have the infor­ma­tion deleted;
  5. Give par­ents the oppor­tu­nity to pre­vent fur­ther use or online col­lec­tion of a child’s per­sonal information;
  6. Main­tain the con­fi­den­tial­ity, secu­rity, and integrity of infor­ma­tion they col­lect from children.

As I read this I, along with Reshan Richards (@reshanrichards) put together a check­list of things that I would need to look for on each of the sites that we use and deter­mine if they are truly COPPA com­pli­ant. A site may actu­ally say that they com­ply with COPPA because they don’t allow chil­dren under the age of 13 to reg­is­ter with their site. Look­ing at each of these site would be some­thing that had to be done and couldn’t be assumed.

In doing so it was sur­pris­ing to see how many of the sites one would assumed were com­pli­ant actu­ally weren’t and what would need to be done in order to comply.

It is also inter­est­ing to note that in order to thwart may of the age ver­i­fi­ca­tion checks all one needs to do is to enter a year of birth that would make you 13 or older… to lie! This is some­thing that is hap­pen­ing more and more often in homes and with par­ents and chil­dren par­tic­u­larly when sign­ing up for site and tools like Face­book and Google.

These sites could com­ply with COPPA, but don’t want to be both­ered by the steps they would need to take in order to become com­pli­ant or their busi­ness model doesn’t sup­port their needs.

Danah Boyd ( gave an inter­view to “On the Media” where she out­lined how par­ents and stu­dents lie to get around the rules of COPPA. Par­ents look at the age restric­tion as a sug­ges­tions and don’t want the gov­ern­ment telling them what to do, with 93% of par­ents say­ing that they should have the final say.

“On The Media” — MP3

Where does that leave things?


There are two lines with the FAQ regard­ing schools and ser­vices direct at schools that I “think” pro­vide schools with some lee­way and allow them to bro­ker parental con­sent (see #2 above).

 “COPPA allows, but does not require, schools to act as agents for par­ents in pro­vid­ing con­sent for the online col­lec­tion of stu­dents’ per­sonal infor­ma­tion within the school context”


” Many schools have imple­mented Accept­able Use Poli­cies (AUPs) or other mea­sures to edu­cate par­ents and stu­dents about in-school Inter­net use. For exam­ple, a school may use the AUP to inform par­ents of what online ser­vices are pro­vided to stu­dents, and the school’s poli­cies regard­ing stu­dents’ use of the Internet.”

A school would need to still ver­ify the other items out­line in order to be com­pli­ant, but by pro­vid­ing writ­ten noti­fi­ca­tion and ver­i­fi­able parental con­sent (make it part of a school’s enroll­ment con­tract for inde­pen­dent schools) a school could the­o­ret­i­cally use these tools.

But is this some­thing that a school should have to take on from a legal and eth­i­cal per­spec­tive? Why can’t it be easier?


Mark Zucher­burg drew a lot of atten­tion to COPPA and the under 13 issue when he said that “My phi­los­o­phy… is that for edu­ca­tion, you need to start at a really, really young age.

We are start­ing at a very young age with our stu­dents. Whether you’re using a ser­vices like Pixie’s K12Share, Edmodo, Twit­ter and Face­book or want you stu­dent to work col­lab­o­ra­tively with Google Docs a school needs to know how these tools fit in with COPPA.

Much to Mr. Zucherburg’s (and my) plea­sure COPPA is under review and until Decem­ber 23, 2011 is seek­ing pub­lic com­ment on the pro­posed amend­ments to “respond to changes in online tech­nol­ogy, includ­ing in the mobile mar­ket­place, and, where appro­pri­ate, to stream­line the Rule.”

If, like me, would wel­come a more stream­lined rule please take a moment to comment.

Until COPPA is fully reviewed and any changes made we need to work within the rules and guide­lines we are given. I for one am look­ing for­ward to changes that will hope­fully address the chang­ing land­scape of learn­ing. As schools move for­ward with their var­i­ous 1:1 learn­ing ini­tia­tives (lap­tops, iPads, BYOD, etc.) and take learn­ing online this will con­tinue to become a big­ger and big­ger issue.

I am curi­ous as to how your school is deal­ing with COPPA and man­ag­ing the use of your online resources and tools. Please leave a com­ment below and share your thoughts.




About William Stites

Currently the Director of Technology for Montclair Kimberley Academy, "Blogger in Chief" for, husband and father to two crazy kids who make me smile everyday.
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  • Anony­mous


    We are just start­ing to encounter these issues and would love to hear what peo­ple have to say. Our main pri­or­ity is get­ting Google Apps for Ed going here. We are also work­ing with Mind­meis­ter, an online mind-mapping tool with social net­work­ing fea­tures owned by a Euro­pean com­pany who wasn’t aware of COPPA here in the US. I’ve asked the legal team here at U of C if there is any spe­cial way they would like me to go about get­ting per­mis­sion — if you have a form or let­ter at this point in time, or know some­one who does and is will­ing to share it, I’d love to see it. 

    Curt L.

    • Anony­mous

      Bill, as you astutely ask — “But is this some­thing that a school should have to take on from a legal and eth­i­cal per­spec­tive?” — our legal team at UC is very con­cerned about lia­bil­ity in act­ing as the par­ents’ agent. I will be curi­ous to see how they land on this matter. 

  • Howard Levin

    Your stuff is really won­der­ful — damn good writer and your work helps all of us flush these issues out. Thank you for all the time and effort you put into your blog. I need to find the time to read it all!