FTC Seeks Comments on Self-Regulatory Guidelines Submitted Under COPPA

The Federal Trade Commission (FTC) has requested comments on proposed
self-regulatory guidelines submitted by the kidSAFE Seal Program under the
safe harbor provisions of the Children’s Online Privacy Protection Rule (the
COPPA Rule). Owned and operated by Samet Privacy, LLC, the kidSAFE Seal
Program identifies itself as “a fast-growing safety certification service and
seal-of-approval program designed exclusively for children-friendly websites,
mobile applications, tablet devices, and other similar interactive services and
technologies.” The program is seeking safe harbor status pursuant to Section
312.11 of the Revised COPPA Rule.

In particular, FTC has asked respondents to consider, among other things,
whether (i) the proposed guidelines provide “the same or greater protections
for children” as those contained in Sections 312.2-312.10 of the Rule; (ii)
“the mechanisms used to assess operators’ compliance with the proposed
guidelines” are effective; (iii) “the incentives for operators’ compliance with
the proposed guidelines” are effective; and (iv) the proposed guidelines
provide adequate means for resolving consumer complaints. FTC will accept
comments on kidSAFE’s application until October 18, 2013. See Federal
Register, September 18, 2013.