英文标题

In the digital age, COPPA is a cornerstone for protecting children’s privacy in the United States. The Children’s Online Privacy Protection Act, or COPPA, governs how websites and apps collect data from kids under 13. Violation scenarios often arise not from malicious intent but from ambiguous data practices, insufficient parental consent processes, or a lack of awareness about what counts as personal information. This article presents common COPPA violation examples, explains why each example matters, and outlines concrete steps to improve compliance and reduce risk.

What COPPA Requires

The core goal of the COPPA rule is to give parents control over what information is collected from their children and how that information is used. A typical COPPA framework includes:

Eligibility: Children under 13 may not provide information without verifiable parental consent; COPPA requires a process that can verify a parent’s identity and authority.
Notice: Operators must provide clear, concise notices describing data practices; the COPPA notice should explain what data is collected, how it is used, and with whom it is shared.
Consent and Minimization: Data collection should be limited; COPPA emphasizes data minimization and consent for sensitive information.
Security and Retention: Safe data handling, storage limits, and deletion options; COPPA sets expectations for safeguarding data.

Common COPPA Violation Examples

Understanding what commonly trips up organizations can help prevent future missteps. Below are typical COPPA violation examples and how they appear in everyday products.

Unverified parental consent for collecting personal data. A game or educational app collects names, emails, or device identifiers from a user under 13 without confirming a parent’s authority. This is a classic COPPA violation because the product is soliciting information from a child without verifiable parental consent.
Using cookies or device IDs for advertising without parental consent. Even if the app claims to be for children, it may set cookies or collect identifiers to build a profile for targeted ads. COPPA violations occur when these practices bypass the parental consent process and do not provide an adequate opt-out or delete mechanism.
Lack of a child-specific privacy policy or opaque disclosures. A site or app claims to protect privacy but fails to provide a distinct privacy policy tailored to kids, or the policy is buried, vague, or filled with legal jargon. This obscures what data is collected and how it’s used, resulting in a COPPA violation.
Data sharing with third parties without consent or notice. Sharing information with marketing partners, analytics providers, or educational publishers can trigger COPPA necessity for parental consent if the data relates to a child under 13. Without consent, this is a violation.
Inadequate age screening or mislabeling of target audience. An app intended for all ages may fail to implement age gates or may misrepresent the age rating, allowing under-13 users to join and provide data, creating a COPPA violation.
Retention of child data after explicit requests to delete or opt out. If a parent or guardian asks to delete a child’s data, and the operator retains or fails to remove it, this is a COPPA breach that can lead to enforcement action.
Use of child data for non-educational purposes. Collecting information for features unrelated to the service’s essential functions—like selling data or using it to train a model—may violate COPPA if no parental consent is present.
Misleading or missing disclosures about data collection practices in apps marketed to families. If a product labeled as kid-friendly hides data practices or uses default settings that collect data, it creates a COPPA risk.

Real-World Scenarios and How They Were Resolved

Consider a mobile game aimed at children that collects device identifiers and emails for sign-in, yet fails to implement verifiable parental consent. In such a case, regulatory authorities could view this as a COPPA violation, leading to enforcement actions. A more subtle scenario involves educational websites that track user activity with cookies and share analytics data with outside partners without parental consent. In practice, these cases illustrate how even well-meaning services can stray into COPPA violations if they do not align with the parental consent framework and notice requirements. Some cases have shown that minor wording changes in the privacy policy, or adding a simple parental-consent flow, can transform a potential violation into compliant operation. The takeaway is clear: transparency about data collection and explicit consent are the bedrock of trust and compliance.

How to Achieve COPPA Compliance

Proactive compliance reduces risk and builds trust with users and parents. Below is a practical roadmap to align with the COPPA rule and reduce the chance of violations:

Audit data collection. Inventory what information your product gathers from all users, especially data from kids under 13. Identify which data would require parental consent under COPPA.
Implement verifiable parental consent mechanisms. If you collect information from children under 13, set up a consent flow that reliably verifies a parent or guardian, using methods that satisfy regulatory standards for verifiability and security.
Provide a clear, kid-specific privacy policy. Create a concise, user-friendly privacy policy for families that explains data practices, retention, and parental rights. Make it accessible from sign-up screens and within the app.
Limit data collection and use. Favor data minimization; collect only what is necessary to provide the service. Prohibit selling data or using it for advertising to minors without consent, and cap data retention.
Control third-party partners and data sharing. Review all vendors and ensure they also comply with COPPA. Use data processing agreements and require contractors to adhere to robust privacy standards.
Enhance age assurance and safety features. Use age gates, content filters, and moderation to prevent under-13 users from bypassing protections. Provide in-app prompts that remind users of privacy controls.
Keep documentation and prepare for enforcement inquiries. Maintain records of consent, policy updates, and data processing practices. If an investigation arises, you can demonstrate ongoing compliance efforts.

Consequences of COPPA Violations

Enforcement actions for COPPA violations can be significant. The FTC has pursued a range of remedies including civil penalties, formal settlements, and injunctive relief. A typical enforcement outcome could involve paying a fine, implementing a corrective action plan, and undergoing ongoing monitoring for compliance. For companies that repeatedly skirt privacy requirements, the penalties can escalate, and a failure to remediate can result in larger fines or restrictions on business operations. Beyond penalties, COPPA violations can damage customer trust and brand reputation, especially when families learn that a service collected or mishandled a child’s data without proper consent. The risk is not merely a financial one; a breach can disrupt product development and force teams to divert resources toward remediation, audits, and compliance updates.

Best Practices and a Practical Checklist

To help teams stay on the right side of the COPPA rule, here is a practical checklist that organizations can adopt as part of their product lifecycle:

Privacy-by-design: Integrate child-protection considerations into product features from the outset; compliance with COPPA should be part of the development process, not an afterthought.
Clear notices: Ensure that privacy notices are easy to read and understand by parents, guardians, and older kids who may be involved in the consent process.
Consent validation: Use robust verification methods; document each consent transaction.
Data minimization: Limit the data you collect from children and avoid collecting sensitive data unless necessary.
Vendor governance: Screen and contract with any third parties who handle child data to ensure they meet COPPA standards.
Access control and deletion: Provide processes for parents to access, rectify, and delete their child’s data; honor deletion requests promptly.
Training and culture: Educate product teams, designers, and marketers on COPPA requirements and privacy ethics.

Closing Thoughts

For businesses, the aim is not to fear regulation but to design products that respect families and comply with the law. COPPA violation examples serve as important cautionary tales that remind us to build trust through transparency, data minimization, and explicit parental consent where required. As the digital landscape evolves, ongoing evaluation and a clear governance framework around child data will help organizations avoid COPPA violations and create safer online experiences for kids.