Internet connected toys and devices collect a wealth of data from children and raise many privacy and security concerns. Yet despite many documented instances of data breaches, inadequate privacy policies, and questionable data sharing, the Federal Trade Commission (FTC) has not taken any enforcement action against a device maker for violating the Children’s Online Privacy Protection Act (COPPA). Our project will assess whether the FTC’s current regulatory framework is sufficient to protect the privacy of children using connected toys. With legal experts at Georgetown Law’s Institute for Public Representation and the help of security and privacy professionals, we will develop and bring to the FTC a test case designed to establish best practices for connected toys under COPPA. Through media and legislative outreach, we will also advance the public’s knowledge about the privacy risks of connected toys and lay the groundwork for future legislation to protect children’s privacy.
Campaign for a Commercial-Free Childhood
IoT and Kids: Testing the Regulatory Framework for Internet-Connected Toys
Consumer Privacy Rights Fund, 2018
The regulatory action we hope to spur would help children throughout the United States. We expect the media coverage of our complaint will educate parents and consumers in the United States about the privacy issues related to internet-connected toys. It is likely we will receive international media coverage as well.