The settlement between VTech Electronics Ltd. and the FTC in the first Internet-connected toys COPPA case is a reminder for companies looking to enter the connected toys space not to forget this child-focused law.
What’s next for VTech? The FTC stated in its press release that it had shared information and coordinated enforcement with the Office of the Privacy Commissioner of Canada under the U.S. SAFE WEB Act. The OPC has stated that it also worked with the Privacy Commissioner for Personal Data for Hong Kong, where VTech is headquartered, which commenced its own compliance check in December 2015. What’s next for everyone else? This case follows a June 2017 update from the FTC in its guidance to businesses about how to comply with COPPA. That guidance specifically mentioned internet-connected toys. This suggests that more FTC scrutiny in this area is likely. Similar actions are coming outside of the US as well, as we reported recently regarding the Genesis Toys’ My Friend Cayla doll case.
Putting it Into Practice: As the internet breaks out of its traditional boundaries of our computer and phones, companies making connected devices geared towards children should keep COPPA and data security issues in mind. Are mechanisms in place to get verifiable parental consent where needed? Is information appropriately secured? These and other questions should be examined according to the FTC and regulators around the globe.