Antitrust Law Daily Wrap Up, PRIVACY NEWS: FTC seeks input on proposed parental consent verification method, (Sep 10, 2013)

By Lynn Stanton,TRDaily

The Federal Trade Commission is seeking comment on a proposed method of verifying parental consent for the collection of children’s data online, which was submitted by Imperium LLC, a technology services company specializing in data quality products for market research and related sectors. A notice of request for public comment will appear in the Federal Register.

Imperium, which has revised its proposal for ChildGuardOnline twice in response to FTC staff comments, is seeking FTC approval under the agency’s Children’s Online Privacy Protection Act (COPPA) rule.

ChildGuardOnline obtains the name and e-mail address of a parent or guardian from a child under 13 seeking to establish a user name and password for a website or mobile application. It then sends an e-mail to the provided address with a URL so that the parent or guardian can view the site and a link for providing consent.

To confirm a child’s identity and age, parents will be asked for the last four digits of his or her Social Security numbers and the name, address, and date of birth. ChildGuardOnline will confirm the information “in real time,” while the parent is still on the site.

“If the supplied information is not verified the parent will be given the opportunity to respond to challenge questions,” Imperium explained in a letter to the FTC. “Challenge, or knowledge-based authentication methods present the parent with a number of ‘out of wallet’ challenge/response questions to establish valid identification. Because the knowledge needed to answer the questions generated is difficult for anyone other than that specific person to know, it provides a highly secure method for validation. Challenge questions can include, for example, previous addresses, phone numbers, etc.”

Parents may visit the ChildGuardOnline portal at any time to review and, if desired, withdraw previously-granted consents.

Comments on the proposed verification method are due Oct. 9.

News: Privacy FederalTradeCommissionNews