The Federal Trade Commission weighs in on Children’s Online Privacy Protection Act (COPPA) compliance during the COVID-19 pandemic:
For Ed Tech:
- COPPA is not a barrier to schools providing robust remote learning.
- Schools can consent on behalf of parents to the collection of student personal information only if such information is used for a school-authorized educational purpose.
- To get consent from a school, provide the necessary COPPA-required notice of data collection and use practices.
- Make the COPPA notice available to parents, and let them review the information collected.
- Review the FERPA, PPRA and any state laws that protect the privacy of K-12 students.
- Consult with your attorneys to review the privacy and security policies of ed tech services you use.
- Give parents a notice of the websites and online services whose collection you have consented to on behalf of the parent.
- Understand how an operator you choose will collect, use, and disclose personal information from students.