IoT Device Companies: The FTC is Monitoring Your COPPA Data Deletion Duties and More

Recent Federal Trade Commission (FTC) activities with respect to the Children’s Online Privacy Protection Act (COPPA) demonstrate a continued interest in, and increased scrutiny of, companies subject to COPPA.  While the FTC has pursued companies for alleged violations of all facets of its COPPA Six Step Compliance Plan, most recently the FTC has focused on the obligation to promptly and securely delete all data collected if it is no longer needed.  Taken as a whole, recent FTC activity may indicate a desire on the part of the FTC to expand its regulatory reach.

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