TIA is the not-for-profit trade association representing all businesses involved in creating and bringing toys and youth entertainment products to kids of all ages.
January 3, 2012 | The Toy Industry Association (TIA)
submitted an industry response on December 23rd, 2011 to the call for
comments on the Federal Trade Commission’s (FTC) proposed
revisions to the Children’s Online Privacy Protection Act
(COPPA). The FTC proposed the amendments to ensure that the
privacy of children online remains protected as technologies evolve, as
well as to help with industry compliance.
With input from its members, TIA prepared comments that reflect the
toy industry’s position on the revisions, several of which could
have a significant impact on toy industry stakeholders if they are
“TIA’s members have a strong commitment to privacy in
general, and to children’s privacy in particular. The proposed
rules include some useful revisions that will facilitate our
members’ ability to offer fun, safe online environments for
children,” stated TIA in its comments. “However, the
proposed rules fundamentally change some long-standing policies which
have proven to be protective of children’s privacy.”
The submitted comments included a discussion on how, in some cases,
the proposed revisions (1) eliminate the common-sense distinction
between personal and non-personal information; (2) restrict the ability
to use anonymous data for research; and (3) eliminate a useful and
widely-accepted method of parental consent.
TIA also joined as a signatory to a set of COPPA comments drafted by
the Kids Privacy Coalition and weighed in on input provided by the
Children’s Advertising Review Unit (CARU) about the COPPA safe
harbor program, a model of recognition by the government of the value of
self-regulation in promoting compliance.
The Association’s comments to the FTC may be viewed in