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The Rule requires you to provide parents with a means of reviewing any personal information you collect online from children. In addition, a child-directed website can’t rely on this exception to treat particular visitors as adults and track their activities. The term “support for internal operations” does not include behavioral advertising.

Importantly, the listed methods are not exhaustive; you may use other methods as long as they are “reasonably calculated” to ensure that the consent is being provided by the parent. For example, you could supplement the request for credit card information with special questions to which only parents would know the answer and find supplemental ways to contact the parent. Even where the child does reveal age-identifying information, if no one in your organization is aware of the post, then you may not have the requisite actual knowledge under the Rule. Where an operator knows that a particular visitor is a child, the operator must either meet COPPA’s notice and parental consent requirements or delete the child’s information.

“Support for internal operations” does, however, include the collection or use of persistent identifiers in connection with serving contextual advertising on the child-directed site. Moreover, in order to meet this one-time contact exception, your e-card system must not allow the sender to enter her full name, her email address, or the recipient’s full name. Nor may you allow the sender to freely type messages either in the subject line or in any text fields of the software download free e-card. In your prize notification message to the parent, you may ask the parent to provide a home mailing address to ship the prize, or invite the parent to call a telephone number to provide the mailing information. At the same time, you should also evaluate your potential liability under Section 5 of the FTC Act.

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In addition, the Rule requires you to give a parent access to any personal information you have collected from the child. Before you provide that information, you will need to confirm that the person requesting the information is the child’s parent. Again, providing the parent a password or a PIN number makes it easier to confirm the parent’s identity if the parent requests access to the child’s personal information. What do I do if some parents cannot or will not use the consent method I have chosen? For instance, some parents might not have a credit card, or might feel uncomfortable providing government identification information online.

Information about applying for FTC approval of a safe harbor program is provided in Section 312.11 of the Rule and online at the COPPA Safe Harbor Program portion of the FTC’s Business Center website. In addition, you may send an email to , and a member of the FTC staff will help answer your questions. However, as a best practice, schools should consider making such notices available to parents, and consider the feasibility of allowing parents to review the personal information collected. See FAQ N.4. Schools also should ensure operators delete children’s personal information once the information is no longer needed for its educational purpose. If a parent revokes consent and directs you to delete the personal information you had collected from the child, you may terminate the child’s use of your service.

The COPPA Rule applies to an operator of a general audience website if it has actual knowledge that a particular visitor is a child. However, you must delete the child’s online contact information from your records promptly after you send your response. You may not use the child’s online contact information to re-contact the child , or disclose the child’s online contact information.

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For example, it could be a deceptive practice to misrepresent the level of oversight you provide for a child-directed app. A mobile phone number is not online contact information and therefore cannot be collected from the child as part of the consent initiation process. However, once you have connected with the parent via the parent’s online contact information, you may request a parent’s mobile phone number in order to further communicate with him or her.