FTC Votes 4-0 to Approve Integrity Children’s Privacy Compliance Program as “Safe Harbor”

Children’s sites get new methods to obtain parental consent; streamlined ‘frictionless’ and ‘commercially reasonable’ methods a boost to business, parent-friendly

Washington, DC ­­ (February 27, 2011) — The Federal Trade Commission (FTC) announced Friday that commissioners voted unanimously to approve The Integrity Children’s Privacy Compliance Program, designed by Aristotle International, as a “safe harbor” program under the Children’s Online Privacy Protection Act (COPPA).

The FTC’s COPPA Rule mandates operators of websites and online services directed to children under the age of 13, and those who knowingly collect personal information from children, must post privacy policies on their sites, notify parents about their information practices, and obtain parental consent before collecting, using, or disclosing any personal information from children. COPPA’s “safe harbor” provision allows industry members and groups the freedom to employ an FTC-approved COPPA oversight program to reduce or eliminate the need for formal FTC investigation and law enforcement.

The Integrity Children’s Privacy Compliance Program protects children’s privacy by helping websites meet the standards established by the FTC, and gives companies more responsible and commercially reasonable ways to obtain parental consent for children online. This innovative application of technology obtains a parent’s clear, unambiguous consent to help children safely enjoy age-appropriate websites.

Integrity can now enable sites that focus on children 12 and younger, and even those that do not, to easily meet COPPA-compliance requirements, by leveraging Integrity’s extensive identity information to empower real-time verification of parents. This is an important safety enhancement in the virtual world and game environments, particularly where immediate approval is desired without the requirement of a credit card.

Most site operators currently rely on “e-mail plus” or require the processing of a credit card charge. The FTC’s new Rule addressing data retention and deletion, proposes to remove “e-mail plus” as an option for obtaining verifiable parental consent because “the Commission believes that e-mail plus has outlived its usefulness and should no longer be a recognized approach to parental consent under the Rule.” Aristotle shares the same view of the e-mail plus option—it is not a reliable method of obtaining parental consent because it is easily subject to circumvention by children. As a result, Aristotle has introduced a number of innovative and frictionless methods for obtaining verifiable parental consent.

Integrity has integrated modern technology into the parental verification process. The 13 online and offline mechanisms include real-time face-to-face verification of parents via Skype or similar videoconferencing technologies. It gives the parents the authority to say, “I am the adult responsible for this child and you may include him or her in this activity.” If a parent says “no”, the child may not participate. Where the provider is an online business, the FTC-approved safe harbor program is insurance against legal exposure and brand risk.

To earn safe harbor approval, the Integrity program had to fulfill three criteria:

  1. Provide the same or greater protections for children as those contained in the Rule;
  2. Set forth effective, mandatory mechanisms for the independent assessment of Members’ compliance; and
  3. Provide effective incentives for Members’ compliance.

Aristotle’s safe harbor application was published in a Federal Register notice June 27, 2011, after which the FTC sought public comment through August 15, 2011. The Commission vote to approve the Aristotle safe harbor application was 4-0.

“This is great news for parents and for their kids, and for responsible marketers and social networking sites,” said Aristotle CEO John Aristotle Phillips. “Companies seeking to communicate effectively with children now have a wide selection of FTC-approved methods to get the explicit consent of parents easily and affordably. After careful study of Aristotle’s Integrity Solution for COPPA Compliance, the FTC’s decision gives marketers a variety of relatively frictionless ways to comply with the law and to engage children. It’s good news for parents and, of course, kids, for whom the online experience should be safe and respectful of their privacy. It is our hope that Aristotle’s FTC-approved Integrity solution will encourage parents and their children to have a conversation about online safety and behavior at the time the child seeks to access websites.

“I want to thank leaders in the field like Nell Minow and Linda Criddle, who supported this application, and the FTC Commissioners who approved it. This approval will benefit the growing number of responsible marketers who have adopted Aristotle’s Integrity solutions for age and identity verification and can now utilize our COPPA-compliant program.”

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Media Contact: Brandi Travis, (202) 903-4221

About Aristotle

Aristotle has delivered smarter tools to political campaigns since 1983. Every U.S. President — Democrat and Republican — from Reagan through Obama, has used Aristotle products and/or services, as have many U.S. Senators, members of the U.S. House of Representatives, Democratic and Republican state party organizations and other major campaigns worldwide.

About Integrity
Integrity services more countries and have greater depth of information worldwide than any other provider with over 135 countries and 3.4 billion records internationally. Changes in country demographics make this important and companies find global coverage is essential in modern borderless internet economies.
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