BBB National Programs Blog

Under COPPA, personal information includes information that can directly identify a child under 13 including their first and last name, home address or precise location, online contact information, or telephone number. If the operator of an online service collects, uses, or shares a child’s personal information, they must provide a notice that explains what they are doing with the personal information. If an operator is sharing personal information with third parties or using it for other purposes such as marketing, they must also get Verifiable Parental Consent (VPC) from the child’s parent or guardian to do so.

To learn more about COPPA, see our blog post “COPPA and Children's Privacy: What Parents Should Know and Do.”

When an app asks permission to access information from your phone, this is different than asking for VPC. App platforms such as Apple and Google require apps to ask for permissions, whereas obtaining VPC is required by law. For VPC to be required when an app asks for personal information, two things need to take place:

1. The child under 13 is the person providing the personal information. If a parent or other person over 13 is the one providing the personal information (such as a parent uploading a photo of their child to Facebook), no VPC is needed as COPPA only applies to information collected directly from children under 13.
2. The app is collecting, storing, or sharing the personal information. If the app saves personal information to its own servers, or discloses it to another company for another purpose, then VPC is required.


To make this distinction clearer, let’s look at a hypothetical app that’s intended for kids under age 13:

Let’s say an app allows kids to edit photos with silly stickers and effects. To let kids upload their own photos for editing, the app asks for permission to access the photo library on the device. If the app’s privacy policy says that the uploaded photos are not collected or stored to the app’s servers, then no VPC is needed. However, if the app’s privacy policy says the photos are collected or stored to the app’s servers, the app needs to ask the parent separately for their consent to collect the photos prior to allowing the child to upload photos to the app. 


Here are three best practices to support safe app usage: 

1. Review the apps’ privacy policy to determine what data it collects, stores, or shares before your child downloads it. The Google Play Store lists all the potential permissions an app may ask for in each Play Store listing. Apple also recently added this information to their App Store with the new release of iOS 14, but until then you can see which permissions an app that you’ve downloaded uses by going to the device Settings. 
2. Decide what kinds of permissions you are okay with your child granting. If you are not comfortable with an app requesting your child’s exact location (even if that information is not stored or shared by the app), then be sure to use your discretion when looking at apps that need location to operate.
3. Talk to your child! Once they are using the app, encourage them to ask you before granting any app permissions. Explain why you may be okay granting some permissions but not others.