“Common Consent Mechanisms” do not require FTC approval
YORK, PA. November 24, 2014 /MobilityWire/ — AgeCheq (www.agecheq.com), ), the company easing mobile app and game publishers’ burden of compliance with the Children’s Online Privacy Protection Act (COPPA) received written response from the Federal Trade Commission regarding its July 27, 2014 application for approval of AgeCheq’s Realtime Common Consent Mechanism as a new method for verifiable parental consent (VPC). The FTC denied AgeCheq’s application on the basis that both the verifiable consent methods and the common mechanism used in AgeCheq’s system are not new, and therefore do not require its approval.
In its letter explaining its ruling, the FTC stated, “The proposed VPC methods used by AgeCheq are already recognized as a valid means of obtaining verifiable parental consent in the Rule, and AgeCheq is free to pursue the development of a common consent mechanism without Commission approval.”
The Commission also set forth its opinion of common consent mechanisms, writing, “A well-designed common mechanism could benefit operators (especially smaller ones) and parents alike if it offers a proper means for providing notice and obtaining verifiable parental consent, as well as ongoing controls for parents to manage their children’s accounts. The Commission believes that such methods could greatly simplify operators’ and parents’ abilities to protect children’s privacy.”
WHAT EXACTLY IS A COMMON CONSENT MECHANISM?
As written, the COPPA regulation describes individual consent mechanisms for each operator. To comply, each individual operator uses an approved consent mechanism to establish a verified relationship with each individual parent whose child wishes to use an app. In a typical family mobile environment with many games from many publishers, a parent could be required to positively identify themselves dozens of times and learn to use dozens of different parental dashboards. With each additional child under 13, the parent’s COPPA burden would simply multiply.
In comparison to these individual methods, common mechanisms allow all operators who use a common system to present parents with a single setup, single-sign-on service with a single dashboard from which they can manage the privacy of multiple children, each with multiple devices, as they use mobile apps and games from an unlimited number of publishers.
“We are very pleased with this clarifying response from the FTC,” said AgeCheq CEO Roy Smith. “We believe common consent mechanisms (CCMs) are the only viable way for mobile app and game publishers with millions of users to comply with COPPA, and uncertainty about the FTCs view of CCMs has been a detriment to compliance efforts. The AgeCheq CCM uniquely serves the compliance needs of all four stakeholders in the mobile ecosystem: the mobile app publishers (sometimes called “operators”), the mobile ad networks and other third parties that are built into apps, the parents who wish to protect their children’s online privacy, and most importantly, the children.”
AgeCheq is committed to advancing COPPA compliance through technology innovation. On October 1, AgeCheq filed a second VPC application with the FTC for a different consent method based on digital signature. The FTC published that application for public comment on November 19th. The company expects to be notified of the FTCs decision on the second application by February 1, 2015.
Link to the FTC response letter: http://www.ftc.gov/system/files/attachments/press-releases/ftc-concludes-review-agecheqs-initial-proposed-coppa-verifiable-parental-consent-method/141121agecheqapplication.pdf
For more information on AgeCheq and its COPPA compliance solutions for developers and parents visit www.AgeCheq.com.
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AgeCheq is a leading provider of cloud-based privacy disclosure, compliance and management services for mobile app and game publishers. AgeCheq’s COPPA compliance service fulfills the industry’s need for a single sign-on “common consent mechanism” allowing parents and publishers to comply with the law in a streamlined way. As the mobile industry’s premier CaaS (compliance as a service) provider, AgeCheq offers app publishers a frictionless path to make their apps and games COPPA compliant. For parents, AgeCheq provides a single point of contact where they can easily see, and approve or disapprove, of what is going on behind the scenes in the apps their children use. AgeCheq is platform-agnostic and can be integrated into an existing app and tested within a day. For more information visit www.AgeCheq.com.
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