COPPA Policy
Specific privacy protections and disclosure requirements for services that collect personal information from children under the age of 13.
What is a COPPA Policy?
Specific privacy protections and disclosure requirements for services that collect personal information from children under the age of 13.
Regulators across USA treat a COPPA Policy as a baseline legal requirement. Without one, your business is immediately exposed to enforcement action — regardless of size or industry.
Who Needs a COPPA Policy?
Apps, games, websites, and online services directed at children or known to be used by them.
- Any organisation that apps, games, websites, and online services directed at children or known to be used by them
- Businesses operating in USA
- Anyone using third-party services that process data on your behalf
Legal Framework
Mandated by the Children's Online Privacy Protection Act (COPPA).
USA
FTC + state laws
What Your COPPA Policy Must Include
- 1
Verifiable Parental Consent (VPC)
Verifiable Parental Consent (VPC) — Clearly define verifiable parental consent (vpc) so users and regulators understand its scope and why it matters for your compliance obligations.
- 2
Notice to Parents
Notice to Parents — Clearly define notice to parents so users and regulators understand its scope and why it matters for your compliance obligations.
- 3
Parental Access & Deletion Rights
Parental Access & Deletion Rights — Clearly define parental access & deletion rights so users and regulators understand its scope and why it matters for your compliance obligations.
- 4
Data Minimization for Minors
Data Minimization for Minors — Clearly define data minimization for minors so users and regulators understand its scope and why it matters for your compliance obligations.
- 5
Prohibition on Behavioral Advertising
Prohibition on Behavioral Advertising — Clearly define prohibition on behavioral advertising so users and regulators understand its scope and why it matters for your compliance obligations.
- 6
Third-party Data Sharing Restrictions
Third-party Data Sharing Restrictions — Clearly define third-party data sharing restrictions so users and regulators understand its scope and why it matters for your compliance obligations.
How to Write a COPPA Policy
Building a compliant COPPA Policy from scratch takes legal expertise and hours of research. Here is a framework covering the core steps:
- 1Step 1: Verifiable Parental Consent (VPC) — Document this section completely and accurately. Vague or incomplete disclosures can be treated as violations even if the underlying practice is compliant.
- 2Step 2: Notice to Parents — Document this section completely and accurately. Vague or incomplete disclosures can be treated as violations even if the underlying practice is compliant.
- 3Step 3: Parental Access & Deletion Rights — Document this section completely and accurately. Vague or incomplete disclosures can be treated as violations even if the underlying practice is compliant.
- 4Step 4: Data Minimization for Minors — Document this section completely and accurately. Vague or incomplete disclosures can be treated as violations even if the underlying practice is compliant.
- 5Step 5: Prohibition on Behavioral Advertising — Document this section completely and accurately. Vague or incomplete disclosures can be treated as violations even if the underlying practice is compliant.
- 6Step 6: Third-party Data Sharing Restrictions — Document this section completely and accurately. Vague or incomplete disclosures can be treated as violations even if the underlying practice is compliant.
- 7Final step: Legal review — Review with qualified legal counsel before publishing, especially if operating in high-risk jurisdictions.
Common Mistakes to Avoid
Copying another website's COPPA Policy verbatim — Every business has different data flows. A generic copy may fail to disclose what you actually do, creating false statements that are worse than no policy at all.
Using vague or ambiguous language — Regulators and courts expect plain, specific language. Phrases like "we may share your data with partners" are too vague and regularly cited in enforcement actions.
Forgetting to update after product changes — Your COPPA Policy must reflect current practice. Outdated policies are a compliance liability — some regulators treat an outdated policy as a violation in itself.
Not making your COPPA Policy easy to find — Buried in a footer or behind multiple clicks, your policy may not meet the "easily accessible" standard required by most regulations.
Missing jurisdiction-specific requirements — A policy compliant in one jurisdiction may still fail in another. If you operate across USA, you need to address each framework's specific requirements.
How Often Should You Update Your COPPA Policy?
At minimum, review your COPPA Policy once a year — and immediately whenever you: change the data you collect, add new third-party tools, enter new jurisdictions, or experience a data incident.
Consequences of Non-Compliance
Beyond financial penalties, non-compliance with COPPA Policy requirements can result in: reputational damage and loss of customer trust, app store removal (for mobile apps), inability to process payments (for ecommerce), and difficulty attracting enterprise customers who require compliance evidence.
Frequently Asked Questions
Is a COPPA Policy legally required?
Yes. A COPPA Policy is a legal requirement under Mandated by the Children's Online Privacy Protection Act (COPPA).. Operating without one puts your business at risk of regulatory enforcement action.
How long should a COPPA Policy be?
A typical COPPA Policy runs 6 pages. Length matters less than completeness — every required disclosure must be present, written in plain language that users can understand.
How often should I update my COPPA Policy?
At minimum, review your COPPA Policy once a year — and immediately after any business change.
What are the penalties for not having a COPPA Policy?
FTC fines can exceed $50,000 per child, potentially reaching millions for large platforms.
Can I use a free COPPA Policy template?
Free templates are a starting point, not a solution. A template that was not drafted for your specific business, jurisdiction, and data practices may create false statements — which is legally worse than having no policy at all. Always customise any template and have it reviewed by qualified counsel.
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Read guidePolicifyAI is a technology provider, not a law firm. The information on this page is for orientation only and is not legal advice. Generated templates are intended as a structured starting point for review by qualified counsel before publication.