TIA Submits Industry Comments on Proposed COPPA Revisions

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 implemented.

“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 full online.