Best Practice for

The Children's Online Privacy Protection Act ("COPPA")

COPPA applies to the online collection of personal information, such as name, home address, email address, telephone number or any other information that would allow someone to identify or contact a child, under age 13.  A web site operator must include in a privacy policy, when and how to seek verifiable consent from a parent and what responsibilities the operator has to protect children's privacy and safety online.  The operator must post a link to a notice of its information practices on the home page of the web site and at each area where personal information is collected from children. The link must be clearly and prominently displayed.

Before collecting, using or disclosing personal information from a child, the operator must obtain verifiable consent from the child's parent.  Verifiable consent means the operator must make reasonable efforts to ensure that before personal information is collected from the child, a parent of the child receives notice of the operator's information practices and consents to those practices.

The better practice, in order to avoid the logistical difficulties in complying with COPPA is to not collect any personal information from children under the age of 16.