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FTC Invites You to Comment on Another COPPA Verifiable Parental Consent Method

Written by Julia Siripurapu

The FTC has announced (press release) that it is seeking public comment on a second verifiable consent method proposed under the Voluntary Commission Approval Process provision of the COPPA Rule. The proponent is Imperium, LLC (“Imperium”), a Connecticut-based technology services company. The Federal Register notice inviting public comment will be published shortly.

The verifiable parental consent solution proposed by Imperium called ChildGuardOnline™ (“Imperium VPC Method”) is a web service that combines several methods for obtaining parental consent enumerated in the COPPA Rule with technical processes that together are designed to enable COPPA-covered entities to comply with their obligation to obtain verifiable parental consent before collecting personal information from children under 13. The Imperium VPC Method consists of a three step process, described below:

  • Validation Process. When a child under 13 begins the process of signing up to obtain a user name and password to use a website, the child will be presented with a page to enter the name and email address of a parent/guardian. The parent/guardian will then receive an email for parental consent, which will include a URL to the website requesting consent and a link for the parent/guardian to use to grant consent. When the parent/guardian clicks on the link to grant permission, he/she must confirm their identity by providing their name, address, date of birth and the last four digits of his/her Social Security Number.
  • Verification Process: Using multiple validation sources, ChildGuardOnline™ verifies the information entered by the parent/guardian in real time. As soon as the parent’s/guardian’s identity has been validated, the parent/guardian as well as the requesting website are notified that the child has been approved to use the website. After the verification process is complete, the parent’s/guardian’s Social Security number is deleted. If the information entered by the parent/guardian is not validated, the parent/guardian will have the opportunity to answer certain knowledge-based questions (e.g., previous address, phone number, etc.) to verify their identity.
  • Parent Portal: As soon as their identity is validated, parents/guardians have access to a password-protected portal where they can view and monitor the websites that they approved for their child’s use and review and/or withdraw previously granted consents. When parental consent is withdrawn for a website, the website is notified and the next time the child attempts to login to the website, he/she will be directed back to the Validation Process described above.

For more information on the Imperium VPC Method, you can read the Imperium application filed with the FTC on August 12th. This is the second revised request for approval submitted to the FTC; the original request was submitted on July 1, 2013 and the revised request was submitted on July 22, 2013. Comments on the Imperium VPC Method may be filed with the FTC online or on paper and mailed to the address set forth in the Federal Register Notice, on or before October 9, 2013.


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Cynthia J. Larose

Member / Co-Chair, Privacy & Cybersecurity Practice

Cynthia J. Larose is Chair of the firm's Privacy & Cybersecurity Practice, a Certified Information Privacy Professional-US (CIPP-US), and a Certified Information Privacy Professional-Europe (CIPP-E). She works with clients in various industries to develop comprehensive information security programs on the front end, and provides timely counsel when it becomes necessary to respond to a data breach.