Children’s Advertising Review Unit (CARU) COPPA Safe Harbor Program

The Children’s Advertising Review Unit (CARU), an investigative division of the advertising industry’s system of self-regulation, has two missions: (1) to protect children from deceptive or inappropriate advertising in all media, and; (2) to ensure that, in an online environment, children’s data is collected and handled in a responsible manner. CARU works with companies to ensure their advertising and data collection practices comply with all relevant laws and CARU’s self-regulatory guidelines, which take into account the uniquely impressionable and vulnerable child audience.

As an extension of its mission to help companies comply with the Children’s Online Privacy Protection Act (COPPA) and properly address the collection and retention of children’s data in an online environment, CARU established its COPPA Safe Harbor Program to provide guidance to companies on how best to comply with COPPA and the CARU Guidelines. Program participants who adhere to CARU’s Guidelines are deemed in compliance with COPPA and essentially insulated from enforcement actions by the Federal Trade Commission (FTC).

CARU COPPA Safe Harbor Program Services

CARU’s COPPA Safe Harbor Program is designed to help your company achieve its business goals while ensuring compliance with CARU’s Guidelines and the COPPA requirements. CARU will support your organization to achieve fulfillment of the program requirements by providing the following services:

  • Comprehensive Audit – CARU staff will guide you through a comprehensive review of any “product”, i.e. website, mobile app, platform or connected device/toy (“IoT”). CARU will evaluate data collection practices for compliance with relevant standards and laws, including:
    • U.S. state and federal laws including but not limited to COPPA, CaCPA, CAN-SPAM
    • CARU’s Guidelines
    • Canada’s PIPEDA and CASL (anti-SPAM) laws
    • Data security/breach laws
  • Advertising Guidance – CARU provides guidance on children’s practices including sweepstakes/contest rules and SMS/MMS campaigns as they apply to your company’s data collection practices.
  • Tracking Assessment – CARU staff will review the entire product including applicable data collection issues/ practices of online/digital advertisements, APIs, plugins, third-party vendors (including but not limited to credit card processors, analytics providers and ad networks) as well as embedded video content to vet all data collection, including first- and third-party trackers.
  • Review/Reconciliation of Privacy Documents – This includes the privacy policy, terms of service and/or EULAs to ensure necessary requirements are met as pertaining to targeting a child audience (directly or indirectly). This includes implementation of short-form privacy policies and upfront/just-in-time consumer notices.
  • Findings Assessment – CARU will provide a written assessment of all issues it finds with the product, as it relates to targeting children (directly or indirectly), as well as clear recommendations and specific direction on next steps to achieve compliance with program requirements and applicable laws.
  • Developer Checklists – CARU will provide “developer checklists” to facilitate privacy by design at outset of product development; these can be tailored upon request and consultation.
  • GDPR Guidance/Consultation – CARU will review and highlight top-level issues and, where applicable, provide referral to BBB EU Privacy Shield to assist with further compliance.
  • Ongoing Guidance – Continued access to lawyers for ongoing counseling via email or phone with fast turnaround and sensitivity to your deadlines. This includes continued review and advice when product content and/or data collection practices change.
  • Regular Monitoring – CARU conducts regular and ongoing reviews of your products to ensure you remain in compliance, alerting you to changes or issues outside of regular compliance reporting periods.
  • Educational Access – As a member of the industry’s leading self-regulatory organization, you’ll have access to quarterly webinars, conferences, guidances, client bulletins and on-site staff visits with privacy training upon request.
  • Advertising Pre-screen Review – For CARU non-supporters, Safe Harbor membership includes one pre-screen, which covers review of scripts, storyboards, “rough cut” draft and/or final edit of advertisements with live action, moving frames, with or without audio (valued at $1,000). Unlimited advertising pre-screen reviews are available to CARU supporters.


CARU COPPA Safe Harbor Program Fees

Fee schedule is available upon request. CARU Supporters receive a 20% discount.

Contact Dona Fraser to learn more about CARU's COPPA Safe Harbor Program and how your organization can become a CARU Supporter.