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.
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.
CDT and Allies Urge FCC Not to Violate Privacy of Cell Phone Buyers
CDT and EPIC led a coalition of 15 organizations in urging the FCC not to require phone companies to collect government IDs, physical addresses, and alternate phone numbers from every phone subscriber in the country.
As Brussels starts emptying for the summer, the risks of frontier AI models continue to capture the attention of policymakers as a key chapter of the AI Act becomes enforceable, and disclosure rules around the use of AI systems and AI-generated content are further clarified.
