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COPPA · COPPA-312-5C4-SCHOOL-AUTH

FTC COPPA FAQs N.1-N.3 — merged into COPPA-312-EDTECH-PROVISIONS

MERGED into COPPA-312-EDTECH-PROVISIONS (legal review, 5 October 2026). Retained for history; not an obligation.

HIGHProcess dutyConsentRegulatory guidanceIn forceApplies from 19 May 2022

Where this comes from

Provision: FTC COPPA FAQs N.1-N.3 — merged into COPPA-312-EDTECH-PROVISIONS

Instrument: Children's Online Privacy Protection Act (COPPA)

Citation: Merged into COPPA-312-EDTECH-PROVISIONS; see that record's citations

Text version: FTC COPPA FAQs section N (staff guidance); 19 May 2022 Commission edtech policy; 90 FR 16918, 16919 (22 April 2025) retains guidance and does not codify school authorization; checked 6 September 2026

Checked against the source: 6 September 2026

Read the official text ↗

Evidence an auditor expects

  • Assessment documentDocument review

    Source-linked COPPA activity, authority and control assessment

    Identify the school-requested educational service, actual authorizing institution and covered activity; a school label alone does not establish consent. Verify the school using a method reasonably calculated to prevent child impersonation; school/district selection is guidance best practice, not a universal statutory signatory rule. Provide direct collection/use/disclosure notice and school review, deletion and prevention-of-further-use/collection controls. Document the limited educational authority and assess direct parental consent separately for other commercial use; preserve operator responsibility. Label the source as FTC guidance and enforcement policy, not a codified 312.5(c)(4) school exception or a verified eligibility finding. Record the exact source version, reviewer, activity and evidence limits. A template or seed is not consent or qualified legal approval.

Questions people ask

From when does this apply?
FTC COPPA FAQs N.1-N.3 — merged into COPPA-312-EDTECH-PROVISIONS applies from 19 May 2022. Its current status is: in force.
What evidence does an auditor expect?
Source-linked COPPA activity, authority and control assessment.

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