COPPA is very different from COPA. COPA was an attempt to force
pornography sites from displaying any offensive images on their home
pages, and it was struck down as unconstitutional.

COPPA on the other hand is designed to protect the identity and other
private information of students online. While there is an exception for
non-profits, they must have an exception under the FTC Act. (Not all
non-profits fall under this category) Since there is an increasing
awareness of privacy and a higher expectation of security, it is wise
to adopt as many of these standards as is possible in order to limit
our exposure to tort lawsuit even if we do have an exception under FTC
Act. Faith based organizations should take the high road and
demonstrate that they care about the individuals coming to their
websites. One way to do this is by informing the individual that the
institution cares about them and is taking steps to protect their
privacy.

The Rule applies to:
● operators of commercial websites or online services, directed at
children under 13, that collect personal information from children;
(this includes collecting email or any other type of contact information)
● operators of general audience sites that knowingly collect personal
information from children under 13; and
● operators of general audience sites that have a separate
children’s area and that collect personal information from children.

The Rule requires these operators to:
● Post a privacy policy on the homepage of the website and link to
the privacy policy everywhere personal information is collected.

● Provide notice to parents about the site’s information collection
practices and, with some exceptions, get verifiable parental consent
before collecting personal
information from children.

● Give parents the choice to consent to the collection and use of a
child’s personal information for internal use by the website, and
give them the chance to choose not to have that personal information
disclosed to third parties.

● Provide parents with access to their child’s information and the
opportunity to delete the information and opt out of the future
collection or use of the information.

● Not condition a child’s participation in an activity on the
disclosure of more personal information than is reasonably necessary for the activity.

● Maintain the confidentiality, security, and integrity of the
personal information collected from children.