COPPA Compliance Checklist for Website Operators
Short answer
A COPPA checklist helps website operators follow the Children’s Online Privacy Protection Act rules when handling personal data from children under 13. Use it to confirm you identify when COPPA applies, collect verifiable parental consent, provide clear privacy notices, limit data collection, allow parental rights, secure data, train your team, and regularly review your policies to stay compliant.
When should you use a COPPA compliance checklist?
If your website, app, or online service collects personal information from children under 13 years old, you must comply with COPPA. This means you need a checklist before launching or updating any feature that could involve kids’ data. For example, if you add chat features, user profiles, or contests that ask for names or emails, COPPA applies. Using the checklist helps you avoid legal trouble and protects kids’ privacy. Even if your main audience is teens 13–17 or older, if younger children can access the site or submit info, COPPA rules still apply. The checklist is also useful if you want to build trust with parents by showing you take privacy seriously. Before starting, learn basics from COPPA Rules Every Website Should Know and What COPPA Stands For.
What are the key steps in a COPPA compliance checklist?
Here is a detailed checklist grouped into stages, explaining why each step matters.
1. Identify if COPPA applies
- Check if your site collects information from kids under 13: Personal information includes names, email addresses, photos, videos, IP addresses, device identifiers, location data, or even persistent identifiers like cookies. For example, if your app asks for a child’s name and email to create a profile, COPPA applies.
- Ask yourself if your content targets children: If your site or app is directed toward kids under 13 or you have actual knowledge kids use it, you must comply. This includes educational games, kids’ social networks, or contests for children.
2. Provide clear privacy notices
- Write a parent-directed privacy policy: Use simple, direct language parents can understand. For example: “We collect your child’s name and email to create an account and send updates. We do not share personal info with advertisers.”
- Explain what data you collect, how you use it, and who you share it with: Include details about data retention and security. For example: “We store your child’s data securely and delete it if you ask.”
- Make the privacy policy easy to find: Place links on your homepage and any page where you collect data. Don’t bury it in fine print or make it hard to find.
3. Get verifiable parental consent
- Use reliable methods to confirm parental permission before collecting data: Examples include sending a consent email that requires a response, requiring a signed consent form sent by mail or fax, or using a credit card charge to verify identity.
- Avoid inadequate methods: Don’t rely on simple checkboxes or digital “I agree” buttons without verification. These do not meet COPPA standards.
- Keep records of all parental consents: Store copies of consent forms, emails, or logs of verification calls. This documentation is essential if your compliance is audited.
4. Limit data collection and use
- Only collect data necessary for the activity: For example, if you offer a newsletter, just collect emails—don’t ask for birthdates or physical addresses unless needed.
- Avoid collecting sensitive data unless absolutely necessary: Sensitive info might include health details or financial information.
- Do not use children’s data for targeted advertising without explicit consent: COPPA restricts behavioral advertising aimed at kids. If you want to advertise, use contextual ads unrelated to personal info collected from children.
5. Allow parental rights
- Provide parents easy access to review their child’s data: For example, create a simple online form or email contact where parents can request information about what you have collected.
- Allow parents to delete their child’s data on request: Explain how they can do this and confirm the deletion promptly.
- Give parents the option to revoke consent at any time: State clearly that withdrawing consent will stop data collection and might limit their child’s access to your service.
6. Secure the data
- Use encryption or other security measures to protect data: For example, use HTTPS on your website and encrypt stored data to prevent unauthorized access.
- Limit access to data internally: Only allow staff who need to handle children’s data to see it, and train them on data privacy.
- Have a data breach plan: Develop a clear process to follow if a data breach occurs, including notifying affected parents and authorities as required.
7. Train your team and review policies
- Train everyone who handles children’s data on COPPA requirements: This includes developers, marketers, customer support, and management.
- Schedule regular policy reviews: Laws and technologies change. Review your privacy policies and consent procedures at least once a year or after any major update to your site or app.
- Test your compliance processes: Perform mock audits or have someone unfamiliar with the site test parental consent flows and privacy notices to catch gaps.
Which COPPA checklist items do people most often skip?
Skipping certain important steps can risk non-compliance:
- Verifiable parental consent: Assuming a checkbox or simple “I agree” click qualifies is a common mistake. Use stronger verification methods like email confirmation or signed forms.
- Parental rights to revoke consent and delete data: Some sites don’t provide easy ways for parents to control their child’s data after giving initial permission.
- Limiting data collection: Collecting more information than needed increases risk. For example, asking for physical addresses when not essential.
- Clear, accessible privacy policies: Many websites have complicated policies hard for parents to understand or that are difficult to find.
- Staff training: Without proper training, team members may unintentionally mishandle children’s data or fail to follow consent processes.
Focusing on these often-skipped steps strengthens your compliance efforts and protects children effectively.
How do you keep your COPPA compliance up to date?
- Monitor official updates: Regularly check the Federal Trade Commission website for any changes to COPPA requirements.
- Review policies after new features: When you add new data collection features such as chat rooms or photo uploads, update your privacy policy and consent forms accordingly.
- Conduct annual audits: Test your site or app’s compliance once a year by verifying consent processes, privacy policy clarity, and data security measures.
- Maintain communication: Keep easy contact channels open for parents to ask questions or make requests about their child’s data. Respond quickly and professionally.
- Document changes and training: Keep records of policy updates and training sessions to show you actively maintain compliance.
Staying proactive helps you avoid costly mistakes and protects the children who use your service.
What if you’re unsure whether COPPA applies to your website or app?
COPPA covers children under 13, so if your audience is mainly teens 13-17 but younger children can access your site, you should act as if COPPA applies. For example, if your app lets anyone create an account and you don’t restrict under-13 users, you must comply. Some parents or kids might lie about their age, so consider requiring age verification. If uncertain, consult beginner resources like COPPA for Beginners: What You Need to Know or talk to a lawyer familiar with online privacy law. Ignoring COPPA can lead to fines or legal enforcement.
How can you test your COPPA compliance before launch?
- Walk through your site or app as a user: Look for every place you collect data—forms, sign-ups, contests—and confirm you have proper consent steps.
- Check your privacy policy: Make sure it’s easy to read and clearly explains data collection and parental rights.
- Simulate the parental consent process: Ask a trusted adult to test it and confirm the verification method is clear and works smoothly.
- Review your data collection forms: Remove requests for unnecessary info. For example, if you only need an email to start, don’t ask for birthday or address.
- Test data security: Confirm secure connections (HTTPS), encryption, and limited staff access.
- Fix any problems before going live: Address potential compliance gaps right away to avoid risks later.
Testing thoroughly helps create a safe, trusted environment for children and parents.
Frequently asked questions
Does COPPA only apply to websites or also apps?
COPPA applies to any online service, including websites, mobile apps, and connected devices that collect personal info from children under 13. It covers all platforms where children might provide data.
Can teens 13 and older give their own consent?
Yes, COPPA protections focus on children under 13. Teens 13 and older usually can provide their own consent for data collection, but check state laws since some have additional privacy rules.
What is "verifiable parental consent"?
Verifiable parental consent means confirming a parent approves data collection through reliable methods such as a signed form, credit card charge, phone call, or government ID verification. Simple checkboxes or clicks don’t meet this standard.
What happens if a website breaks COPPA rules?
The Federal Trade Commission can investigate and impose fines or require corrective actions. Violations can damage your reputation and lead to legal trouble, so full compliance is critical.
Do I need a lawyer to comply with COPPA?
While not required, consulting a lawyer can help in complex cases or if your site collects a lot of children’s data. For basic compliance, many free resources and guides are available to help you follow the rules.
How often should I update my COPPA compliance checklist?
Review and update it at least once a year or whenever you add new features or change your data collection practices to stay aligned with current laws and technology.