The Federal Trade Commission recently posted a blog entry reminding companies about the deletion requirements under the Children’s Online Privacy Protection Act. Namely, that companies under the Act must give parents the right to review and delete their children’s information. In addition COPPA also requires companies to delete children’s personal information when the information is no longer necessary to fulfill the purpose for which it was originally requested. An example given is when a parent decides not to renew a subscription on behalf of their child. In that case, the company must delete the information even if the parent has not specifically requested deletion. The FTC recommends that companies make sure that their document retention policies take into account the stated purposes for which children’s personal information is collected, and under what circumstances the information will no longer be needed for those purposes. The FTC also recommends that companies ensure that they have secure deletion practices in place.
Putting it Into Practice: Companies who collect personal information about children under 13 should keep in mind that the FTC is thinking about COPPA’s deletion requirements. These include not only if a parent asks for deletion, but also when the information is no longer needed.