Understanding COPPA Violations: A Practical Guide for Online Services
What COPPA Is and Who It Protects
COPPA stands for the Children’s Online Privacy Protection Act, a U.S. federal law designed to shield the personal information of children under 13. It applies to operators of online services, websites, and apps that collect, use, or disclose information from kids, or that have actual knowledge that they are collecting such information. The intent is simple: give parents control over what data their children share online and how that data is used. For companies, this means structuring data collection practices, consent processes, and user experiences with kids’ privacy in mind.
What Counts as COPPA Violations
A violation occurs when an online service collects personal information from a child under 13 without obtaining verifiable parental consent, or fails to provide a proper privacy policy and notice about data practices. Personal information includes names, addresses, email addresses, social media handles, location data, photos, voice recordings, or any other data that could identify a child. In addition to direct collection, COPPA violations can arise from:
- Collecting information from a child without providing notice and parental consent.
- Failing to include a clear privacy policy that describes data collection, use, and sharing practices.
- Offering services to children under 13 without implementing age screening or parental-consent mechanisms.
- Sharing or selling a child’s data with third parties without proper disclosures and safeguards.
- Not honoring parental rights to review, delete, or limit the use of their child’s information.
Companies sometimes slip into COPPA violations through suggested misdirection—presenting a kid-directed experience while secretly gathering data through cookies and trackers without consent. Even if a platform has a general audience, if it knowingly targets or attracts kids, COPPA obligations can still apply.
Common Scenarios That Lead to COPPA Violations
Many violations occur in everyday digital environments. Understanding these scenarios helps teams identify risk early:
- Children’s apps collecting location or contact information without parental consent.
- Educational platforms that collect student data beyond what is necessary for the service.
- Third-party analytics or advertising scripts embedded on kid-facing pages that accumulate data without parental consent.
- Marketing campaigns that direct kids to sign up or submit personal details without a verifiable parental consent flow.
- Inadequate or misleading privacy notices that fail to explain data practices clearly to parents.
Penalties and Enforcement
The Federal Trade Commission (FTC) enforces COPPA. Violations can lead to significant penalties, including civil penalties that can reach tens of thousands of dollars per violation. In practice, the penalty amount depends on factors such as the severity, duration, and extent of the violation, as well as a company’s prior history and efforts to remediate. Beyond fines, enforcement can require service changes, independent audits, and ongoing compliance programs.
In addition to federal enforcement, state Attorneys General may bring actions, and civil settlements often include obligations to implement robust privacy protections, undergo regular compliance reviews, and provide ongoing disclosures to parents.
How to Avoid COPPA Violations: Practical Steps
Building a compliant product from the ground up reduces risk and creates trust with parents and users. Here are practical steps to minimize COPPA violations:
- Assess applicability: Determine whether your service is directed to children under 13 or has actual knowledge that it collects information from kids. If yes, implement COPPA-compliant processes even if your primary audience includes older users.
- Clear parental-consent flow: Use verifiable parental consent mechanisms (e.g., email verification, credit card verification, or other reliable methods) before collecting any personal information from a child.
- Transparent privacy policy: Publish a straightforward, kid-friendly privacy policy that explains what data you collect, how you use it, with whom you share it, and how parents can exercise their rights.
- Data minimization and purpose limitation: Collect only what is necessary for the service and avoid using data for secondary purposes without consent.
- Age screening and safeguards: Implement age gates or screening questions to determine user age, and tailor data handling accordingly. If a user is under 13, route to a COPPA-compliant flow or decline access.
- Parental rights and controls: Provide parents with access to review, delete, or modify their child’s data, and to revoke consent at any time.
- Third-party vendors and integrations: Conduct due diligence on any analytics, advertising, or social plugins used on kid-facing pages. Ensure vendors comply with COPPA and have data-processing agreements in place.
- Security and data retention: Use robust security measures to protect data and set clear retention periods that minimize storage of information after it is no longer needed.
- Documentation and governance: Maintain records of consent and data practices. Establish an internal COPPA-compliance policy and assign a responsible privacy owner.
- Ongoing monitoring and training: Train product and marketing teams on COPPA requirements and perform periodic privacy assessments and DPIA-like reviews for kid-focused features.
A Practical COPPA Compliance Checklist
- Is your product directed to children under 13 or does it knowingly collect data from them?
- Do you have a verifiable parental-consent mechanism before collecting personal data?
- Is there a publicly accessible and understandable privacy policy explaining data practices?
- Are you collecting only data that is strictly necessary for the service?
- Have you established a process for parents to review, delete, or opt out of data collection?
- Are third-party services screened for COPPA compliance and bound by data-processing agreements?
- Do you have data security measures and a defined data-retention policy?
- Is there ongoing staff training and regular compliance reviews?
Case Studies and Real-World Learnings
Several high-profile settlements highlight how quickly COPPA violations can escalate and the importance of proactive governance. For example, platforms that failed to obtain parental consent for kids’ information or that relied on non-verifiable consent mechanisms faced swift action and mandatory corrective steps. The takeaway is clear: prioritize a verifiable, auditable consent flow; maintain transparent disclosures; and implement vendor oversight from day one. Even seemingly minor lapses, such as vague privacy notices or inconsistent data handling practices, can trigger enforcement actions and harm a brand’s reputation.
Putting It All Together: Building Trust Through COPPA Compliance
When you design with COPPA in mind, you’re not just avoiding penalties—you’re building a safer product that earns the trust of parents and educators. Clear communication, careful data handling, and strong governance help ensure the user experience remains respectful and compliant. In the long run, this approach reduces risk, improves retention, and supports responsible innovation in family-friendly digital services.
Final Thoughts
COPPA violations can carry serious consequences, but they are largely preventable with a thoughtful, proactive privacy program. Start by evaluating whether your service touches kids under 13, then implement verifiable parental-consent mechanisms, transparent disclosures, and solid data-management practices. Regular training and vendor oversight close the loop, turning regulatory compliance from a checkbox into a core competitive advantage. By prioritizing parental trust and robust data protections, online services can thrive while respecting children’s privacy.