Just in time for Christmas, the Federal Trade Commission (“FTC”) has unveiled its long-anticipated update to the Children’s Online Privacy Protection Rule (“COPPA Rule”).  The COPPA Rule, which has been in place since 1999, imposes a variety of privacy requirements on “operators” of websites and online services that are “directed to children” under 13 or have actual knowledge that they are collecting “personal information” from children.  Among other requirements, such operators must provide…

Carrying out a plan announced earlier this year, the Federal Trade Commission (“FTC”) convened a day-long public workshop on “The Big Picture: Comprehensive Online Data Collection” on December 6, 2012.  The workshop was intended to examine the practices and privacy implications of “comprehensive” data collection about consumers’ online activities.  Data collection capabilities of entities like Internet service providers and operating systems were discussed, but many speakers also focused heavily on data collection for advertising purposes…

The Federal Trade Commission (“FTC”) has released a new set of proposed amendments in its ongoing review of its Children’s Online Privacy Protection Act (“COPPA”) regulations. These amendments would alter key definitions in the COPPA regulations, modifying the FTC’s original proposal from September 2011. If finalized, the FTC’s proposals to date will significantly change who and what COPPA covers and when COPPA applies. Comments are due by September 10, 2012. WHO is responsible for COPPA…