There are some additional limitations on this policy. It does not apply when the operator requests personal information, such as a child’s name. Moreover, the operator may not use the recording for any use other than translation into text, such as behavioral targeting or identification purposes, before deleting it. If the operator does plan to collect other types of personal information, then it would be required to obtain parental consent.
Although the policy provides some clarification about the application of COPPA to voice-capture technologies, operators of child-directed services that collect children’s voices should ensure that their privacy policies and consent and notification procedures comply with COPPA requirements. Violators are liable for up to $40,654 in civil penalties per violation.
Associate Lauren Myers contributed to this post. She is practicing under the supervision of principals of the firm who are members of the D.C. Bar.