I recently read about an interesting new social media site directed to children named Kuddle.

It is basically instagram for kids, but is also intended to teach children netiquette. The software has limited functionality and some additional protections built into it. While it seems like a fairly simple social media app, creating something like this in the U.S. could actually be quite difficult to navigate in the U.S.

Is your website geared to children? Are you aware that your website is collecting personal information from children under the age of 13?

If you answered, "no" to both of these, consider putting a provision in your terms of use prohibiting children from using your site and sighing a big sigh of relief.

If you said "yes" to either of these questions, the Children's Online Privacy Protection Act (COPPA) was made for you.

More likely, you answered "what is personal information?"

The FTC considers personal information to include the following according to its amended rule:

  • First and last name;
  • A home or other physical address including street name and name of a city or town;
  • Online contact information;
  • A screen or user name that functions as online contact information;
  • A telephone number;
  • A social security number;
  • A persistent identifier that can be used to recognize a user over time and across different websites or online services;
  • A photograph, video, or audio file, where such file contains a child's image or voice;
  • Geolocation information sufficient to identify street name and name of a city or town; or
  • Information concerning the child or the parents of that child that the operator collects online from the child and combines with an identifier described above.

If your website (or app) is collecting this type of information from children, please continue reading Part II of this post and review the FTC's website on the subject of COPAA.

Originally published September 19, 2014

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.