The FTC is in the process of moving COPPA enforcement duties from the Division of Advertising Practices (DAP) to its Division of Privacy and Identity Protection (DPIP)
This seems like a logical transition, as DPIP enforces statutes and rules related to consumer privacy, while Ad Practices is tasked with protecting consumers from unfair or deceptive advertising and marketing practices that raise health or safety concerns. According to an FTC representative, the move was driven by the Agency’s desire to coordinate COPPA enforcement with general privacy enforcement and leverage DPIP’s privacy expertise.
We believe that this is helpful information for companies that may be in the process of evaluating its COPPA options because it suggests that COPPA enforcement under the new rules will likely be even more robust than before. Please don’t hesitate to contact us regarding any COPPA related issues.