COPPA 16 CFR 312.4(b), (c)(1)-(4) - Assess and implement the applicable direct notice
Assess the direct-notice pathway and deliver its complete contents and material-change notice where required
Where this comes from
Provision: 16 CFR 312.4(b), (c)(1)-(4) - Assess and implement the applicable direct notice
Instrument: Children's Online Privacy Protection Act (COPPA)
Citation: 16 CFR 312.4(b), (c)(1)-(4) and 312.5(a), (c); 90 FR 16918 (22 April 2025), effective 23 June 2025, general compliance date 22 April 2026
Text version: 16 CFR 312.4 and 312.5(c), eCFR displayed through 3 September 2026, retrieved 6 September 2026; 2025 final rule, 90 FR 16918
Checked against the source: 6 September 2026
Who it applies to
It applies when all of these are true:
- COPPA assessed activity Q_COPPA_COVERED_ACTIVITY: YES
What engineering work it implies
Sample acceptance criteria Landfall generates for this obligation:
- Assess the covered activity and full 312.5(c) pathway before selecting direct-notice contents; do not collect parental contact information merely to complete this assessment.
- For consent notice, include any preliminary name/contact collection, required consent and no further collection/use/disclosure without it, intended information/uses/disclosure opportunities, recipients or specific categories including the public, purposes and the separate choice, online notice link, verifiable-consent means and applicable name/contact deletion.
- Reconcile reasonable-time deletion from notice under 312.4(c)(1)(vii) with deletion measured from collection under 312.5(c)(1); later notice cannot restart retention.
- For participation updates, state parental contact collection, no other use/disclosure, refusal/deletion procedures and the online notice link.
- For repeated contact, state both contact collections, no other use/disclosure/combination of the child's contact, refusal and deletion of both contact sets, stated-purpose effect of no response and the online notice link; undeliverable notice fails reasonable efforts.
Evidence an auditor expects
- Assessment documentDocument review
Notice assessment, contents and operational evidence
Source-version and activity-specific notice assessment with implemented evidence: Assess the covered activity and full 312.5(c) pathway before selecting direct-notice contents; do not collect parental contact information merely to complete this assessment. For consent notice, include any preliminary name/contact collection, required consent and no further collection/use/disclosure without it, intended information/uses/disclosure opportunities, recipients or specific categories including the public, purposes and the separate choice, online notice link, verifiable-consent means and applicable name/contact deletion. Reconcile reasonable-time deletion from notice under 312.4(c)(1)(vii) with deletion measured from collection under 312.5(c)(1); later notice cannot restart retention. For participation updates, state parental contact collection, no other use/disclosure, refusal/deletion procedures and the online notice link. For repeated contact, state both contact collections, no other use/disclosure/combination of the child's contact, refusal and deletion of both contact sets, stated-purpose effect of no response and the online notice link; undeliverable notice fails reasonable efforts. For child safety, state child/parent name/contact collection, safety-only use/disclosure, refusal/deletion procedures, stated-purpose effect of no response and the online notice link. Test receipt efforts, refusal, deletion and material changes requiring renewed notice/consent; a link-only message or parental silence is not general consent. Preserve minimized status and notice-version evidence. A generated task or DRAFT source is not consent, an exception determination or legal approval.
Questions people ask
- Does COPPA 16 CFR 312.4(b), (c)(1)-(4) - Assess and implement the applicable direc… apply to my service?
- It applies when COPPA assessed activity Q_COPPA_COVERED_ACTIVITY: YES.
- From when does this apply?
- COPPA 16 CFR 312.4(b), (c)(1)-(4) - Assess and implement the applicable direc… applies from 22 April 2026. Its current status is: in force.
- What evidence does an auditor expect?
- Notice assessment, contents and operational evidence.
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Not legal advice. Landfall maps regulatory obligations to engineering work for planning purposes. Its verdicts are not legal advice and create no attorney-client relationship — verify with qualified counsel before relying on them.