The Federal Trade Commission recently announced its settlement with the operator of www.skidekids.com concerning allegations that the operator violated the Children’s Online Privacy Protection Act Rule (“COPPA Rule”) by collecting personal information about children without obtaining parental consent. For Skid-e-kids, the FTC’s settlement means taking remedial measures; an injunction; and a $100,000 civil penalty. For the rest of us, the settlement is a good reminder that the FTC is staunchly committed to protecting children’s privacy. So when it comes to collecting personal information from children online, it’s important to do it right . . . or not at all.
Today, at the urging of Members of Congress, the Federal Trade Commission (“FTC”) announced that it will delay enforcement of its Red Flags Rule for the fourth time. Financial institutions and creditors subject to enforcement by the FTC will now have until June 1, 2010 to develop written policies and procedures to detect and respond… Continue Reading
Section 315 of FACTA requires institutions that utilize consumer reports (“users”) to develop and follow certain procedures when notified of an address discrepancy by a national CRA (Equifax, Experian and TransUnion). Under FACTA, national CRAs are required to issue a “notice of address discrepancy” when an address provided by a user requesting a consumer report “substantially… Continue Reading
On February 12, 2009, the FTC issued its long-anticipated Staff Report on Self-Regulatory Principles for Online Behavioral Advertising. The revised Self-Regulatory Principles are the result of a year of study of the more than 60 comments provided by industry, advocacy organizations, academics, and individual consumers in response to the FTC’s proposed self-regulatory principles issued in late 2007.