COPPA Compliance Guide

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  1. COPPA Compliance Guide

This guide provides a comprehensive overview of the Children's Online Privacy Protection Act (COPPA) and how it applies to websites and online services, especially those hosted on platforms like MediaWiki. It's geared towards beginners and aims to demystify the regulations involved in protecting the online privacy of children under 13. Understanding and adhering to COPPA is crucial for avoiding legal repercussions and maintaining user trust.

    1. What is COPPA?

The Children's Online Privacy Protection Act (COPPA) is a US federal law enacted in 1998. Its primary goal is to put parents in control over what information is collected from their young children online. The Federal Trade Commission (FTC) enforces COPPA, and violations can result in substantial penalties.

Specifically, COPPA applies to website operators and online service providers who *knowingly* collect, use, or disclose personal information from children under the age of 13. "Knowingly" is a key term; it means the operator has actual knowledge, or is aware of facts that would lead a reasonable person to believe, that the information is being collected from a child. This awareness can be established through various means, including explicitly asking users for their age, or through the nature of the content and services offered.

    1. Who Does COPPA Apply To?

COPPA isn't a blanket regulation for *all* websites. It primarily targets:

  • **Websites and Online Services Directed to Children:** If your website or service is specifically designed for, or likely to be used by, children under 13, COPPA applies. This is determined by considering the content, advertising, language used, and overall appeal of the site. A Wiki Design focused on cartoons, for example, would likely be considered directed to children.
  • **Operators of General Audience Websites:** Even if your website isn’t specifically *aimed* at children, COPPA still applies if you *knowingly* collect personal information from children under 13. This is a crucial point. A MediaWiki Extension that allows user accounts, even on a general interest wiki, is subject to COPPA if it collects information from children without parental consent.
    1. What Constitutes "Personal Information" Under COPPA?

COPPA defines "personal information" broadly. It includes anything that can be used to identify a child individually, such as:

  • **First and Last Name**
  • **Home or School Address**
  • **Email Address**
  • **Telephone Number**
  • **Photographs**
  • **Audio and Video Recordings**
  • **Geolocation Information**
  • **Online Identifiers** (e.g., username, IP address, unique device ID)
  • **Any other information that, alone or in combination with other information, could reasonably be used to identify a child.**

Even seemingly innocuous data points, when combined, could be considered personal information. For instance, a child’s birthday and city of residence, combined with their favorite color, could potentially identify them.

    1. The Core Principles of COPPA Compliance

There are several key principles to understanding COPPA compliance:

1. **Notice:** You must provide a clear, understandable, and conspicuous privacy policy on your website. This policy must detail what personal information you collect from children, how you use it, and how you protect it. This is often linked in the Website Footer.

2. **Parental Consent:** Before collecting, using, or disclosing personal information from a child under 13, you *must* obtain verifiable parental consent. There are several methods for obtaining this consent, each with its own requirements (see the section on "Verifiable Parental Consent" below).

3. **Data Security:** You must take reasonable measures to protect the security of children’s personal information. This includes implementing appropriate technical safeguards, such as encryption and access controls. Consider a Security Audit regularly.

4. **Limited Data Collection:** Only collect the minimum amount of personal information necessary for the specific purpose for which it is collected. Avoid collecting information you don't need. Data Minimization is a key principle.

5. **Data Use Limitation:** You can only use children’s personal information for the purposes disclosed in your privacy policy and for which parental consent was obtained. You cannot share or sell their information to third parties without explicit consent.

6. **Data Retention:** You must retain children’s personal information only for as long as necessary to fulfill the purpose for which it was collected. Establish a clear Data Retention Policy.

7. **Parental Access, Correction, and Deletion:** Parents have the right to review the personal information collected from their children, correct any inaccuracies, and request that the information be deleted. You must provide a mechanism for parents to exercise these rights.

    1. Verifiable Parental Consent: Methods and Requirements

Obtaining verifiable parental consent is the most challenging aspect of COPPA compliance. The FTC has outlined several acceptable methods:

  • **Direct Notice & Consent:** This involves providing parents with direct notice of your information collection practices and obtaining their consent directly. This can be done through email, a postal mail form, or a phone call. The method must be reasonably designed to ensure that the person providing consent is actually the parent.
   *   **Email:** Requires a valid email address and a method to confirm the parent’s identity.
   *   **Postal Mail:**  Requires a signed and returned consent form.
   *   **Phone Call:** Requires verbal confirmation from the parent and a record of the call.
  • **Knowledge Attribute Method:** This involves using a reasonable method to determine whether the person providing consent possesses knowledge about the child. This is generally not recommended as it's difficult to prove the reliability of the method.
  • **Third-Party Verification Services:** These services specialize in verifying parental identity and obtaining consent on your behalf. Examples include vendors like AgeCheck or IDology. This is often the most practical solution for larger websites. Third-Party Integration can streamline this process.
  • **School Consent:** If you are collecting information from children through a school, you must obtain consent from the school.
    • Important Considerations:**
  • **Consent is not transferable:** Consent obtained for one purpose cannot be used for another.
  • **Consent can be withdrawn:** Parents have the right to withdraw their consent at any time.
  • **Consent must be documented:** You must keep records of all parental consent obtained.
    1. COPPA and MediaWiki: Specific Considerations

Implementing COPPA compliance on a MediaWiki platform requires careful consideration. Here's how COPPA impacts common MediaWiki features:

  • **User Accounts:** Creating user accounts inherently involves collecting personal information (username, email address, IP address). If your wiki is directed to children or you knowingly collect information from children, you *must* obtain parental consent before allowing children to create accounts. Consider disabling account creation altogether or restricting it to users who can verify they are 13 or older. A User Registration Policy is essential.
  • **Forms and Surveys:** Any form or survey that collects personal information from users, including children, requires parental consent.
  • **Comments and Discussion Forums:** If your wiki has comment sections or discussion forums, you need to consider how children might share personal information in those spaces. Implement moderation tools and policies to remove any personal information shared by children without parental consent.
  • **File Uploads:** Allowing users to upload files (images, videos, etc.) can also lead to the sharing of personal information. Implement safeguards to prevent children from uploading photos or videos that reveal their identity.
  • **Statistics and Analytics:** Even collecting seemingly anonymized data, like IP addresses, can be considered collecting personal information under COPPA. Ensure your analytics tools are configured to comply with COPPA (e.g., IP address anonymization). Review your Website Analytics setup.
  • **MediaWiki Extensions:** Any extension that collects personal information must be evaluated for COPPA compliance.
    1. Practical Steps for COPPA Compliance on MediaWiki

1. **Assess Your Wiki:** Determine whether your wiki is directed to children or whether you knowingly collect information from children. 2. **Develop a Privacy Policy:** Create a clear and comprehensive privacy policy that explains your information collection practices. Link it prominently on your wiki (e.g., in the footer). 3. **Implement Age Screening:** Implement a mechanism to screen users for age. This could involve requiring users to confirm they are 13 or older before creating an account. Consider using a Age Verification Plugin. 4. **Obtain Parental Consent:** If you collect information from children, implement a verifiable parental consent process. A third-party verification service is often the most efficient solution. 5. **Secure Your Data:** Implement appropriate security measures to protect children’s personal information. 6. **Train Your Staff:** Ensure that anyone involved in managing your wiki understands COPPA requirements. 7. **Regularly Review and Update:** COPPA regulations can change. Regularly review and update your privacy policy and compliance procedures.

    1. Resources and Further Information
    1. Disclaimer

This guide provides general information about COPPA and is not intended as legal advice. You should consult with an attorney to ensure your website or online service is fully compliant with all applicable laws and regulations. This is especially important given the complexities of Legal Compliance.

Main Page

MediaWiki Security

Privacy Policy

User Rights Management

Extension Development

Website Administration

Data Backup

Server Configuration

Content Management

Legal Considerations

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