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Protecting Children’s Privacy is Not Just Fun and Games

March 2, 2015 —

It’s not often that a student gets to officially play with a kids’-themed mobile app in a class, let alone a clinic. But the clinic was the Institute for Public Representation, and in the fall of 2013, Yena Kwon (L’15) was trying to determine whether this particular app — featuring the “Hello Kitty” cartoon character — complied with the Children’s Online Privacy Protection Act (COPPA). 

“Part of my research was playing this game — a lot,” admits Kwon. “People would kind of be looking over at me and going, what are you working on? [And I’d say,] it’s actually hard; I’m looking at all the different aspects of this game.”

But it wasn’t all fun and games. After a consultation with a digital technologist, Kwon, clinic fellow Eric Null (LL.M.’15) and IPR co-director Angela Campbell would present their findings to the FTC and later submit, in December 2013, a complaint asking the FTC to investigate the “Hello Kitty Carnival” app on behalf of their client, the Center for Digital Democracy. 

The complaint alleges that the app’s creator, Sanrio, and third parties can unlawfully access and collect at least three different types of personal information from children, including the mobile device’s location and photographs of kids. “I think there’s value in bringing these issues to the forefront,” said Kwon, who along with Null and Campbell presented their work at a lunchtime pizza session on February 27, as a White House bill to protect consumer privacy made news outside. 

Campbell and Professor Alvaro Bedoya, executive director of the Center on Privacy and Technology, introduced the event.

Campbell’s Communications and Technology Law section of the clinic has been involved with children’s media issues since the 1990s, when its work on a fledgling Internet influenced both the passage of COPPA in 1998 and updates for a smart-phone era in 2013. (And we should mention that as the head of the FTC’s Consumer Protection Bureau during that time, Professor David Vladeck and his team was responsible for updating the regulations.)

While their work has yet to receive official action from the FTC, the IPR has continued the fight to protect children’s privacy on other projects relating to COPPA. 

“Part of what we want to do is ensure that all these new and exciting apps for children and websites that are directed at children are actually complying with the law and are protecting children’s information,” explains Null. “So as time goes on, we will continue to investigate those new apps and services.” 

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