CDT Files Comments with FTC in Response to COPPA Updates
On March 11, CDT filed comments with the Federal Trade Commission in response to their proposed updates to the Children’s Online Privacy Protection Act (COPPA) Rule. In the comments, we make several arguments:
The COPPA Rule should include strong data minimization requirements;
The FTC should strengthen and adopt its proposals around direct notice, verifiable parental consent mechanisms, and retention and deletion of children’s data;
The definitions of biometric data and inferred data should be clarified, as should requirements around content personalization;
The “child directed” determination should include, as proposed, a totality of the circumstances analysis, and the FTC should not require “constructive knowledge”; and
The proposed educational exception to parental consent should be adopted with several important changes.
Coalition Urges Senate Not to Let Companies Waive Financial Regulations for AI
CDT joined AI Now Institute, American Civil Liberties Union, and several organizations dedicated to tech policy, consumer protection, and civil rights in a letter to Senate leadership and the Senate Banking, Housing, and Urban Affairs Committee opposing the “AI Innovation Labs” language in Sec. 10509 of the CLARITY Act.
Potential Avenues for Redress for AI-related Harms under EU Equality and Non-Discrimination law: A Visual Explanation
In this third instalment of the series, we look at the opportunities afforded by EU equality and non-discrimination law in providing redress for AI-related harms.
CDT and Partners Urge Passage of the California Location Privacy Act of 2025 (AB 322)
Location data is particularly sensitive, and when collected across time it can reveal a broad range of intrusive insights such as medical conditions, sexual orientation, political activities, and religious beliefs.
