How to implement COPPA-compliant push notifications in your kids app
Push notifications are a useful tool for re-engaging users and getting kids back into your app. Under both COPPA and GDPR-K, sending push notifications to kids is deemed collecting personal information, similar to an email address, and therefore requires an appropriate level of parental consent to enable.
Under COPPA (applicable to your US audience), certain types of push notifications can be activated without first obtaining parental consent (though parents need to be informed and given the opportunity to opt out). This is known as the “multiple-contact exception.”
With this approach, you can ask the child to enable push notifications, so long as:
1. You don’t combine any other personal data collected from the child with the push notification, e.g. you can’t personalise the message by including the child’s name, for example, even if that name was collected in compliance with COPPA.
2. At the point of requesting the push notification permission (or before) you obtain the parent’s email address. You must then provide the parent with notice that the child has enabled notifications and give the parent a way to opt out. This is called Direct Notice.
3. Your push notifications may only contain information about your app and that is relevant to the child’s activities in the app. For example, a notification that new content is available in a channel the child has followed. You may not send marketing messages about other products..
So what does this mean for you as an app developer?
You can enable push communication with your users without having to go through a full verifiable parental consent process, so long as you stick to the ground rules above. Remember it is always best to communicate clearly to parents about your data privacy practices and how your protect their children in your app.
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Originally published at blog.superawesome.com on December 5, 2018.
