The State of Play: Verifiable Parental Consent and COPPA

> The State of Play: Verifiable Parental Consent and...

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Executive Summary

Today, many children’s favorite playgrounds are found online. And verifiable parental consent, or VPC, is the digital version of giving a child permission to play. 

The challenges and opportunities posed by VPC have never been more important. Young people are using online services more than ever. Parents are grappling with how to protect their children best while teaching them to engage with technology in healthy ways. The Federal Trade Commission (FTC) is considering changes to the core federal law governing VPC. Companies are developing and implementing novel VPC technologies.

New laws in California, Utah, and the United Kingdom require that a range of online services begin estimating or verifying the age of users, which will invariably impact the use of VPC methods. Indeed, some of the same technologies used to establish VPC also undergird age estimation technologies required by these new laws. Stakeholders have started a robust discussion about the potential benefits of age estimation and VPC tech, the privacy risks of estimating the ages of internet users, and the trade-offs between the accuracy and invasiveness of VPC and age estimation technologies. Therefore, it is an excellent time to assess the state of play regarding VPC.

With that ambition, FPF convened industry, advocates, academics, parents, and policymakers to better understand how VPC works today, how it impacts kids’ access to online play, and the unintended consequences of VPC laws and technologies. We prepared a discussion draft of this whitepaper last fall and circulated it widely to both stakeholders and the public, inviting commentary and feedback. This is the revised version of the discussion draft: an updated analysis of the state of play.

In this paper, we examine just how much children engage with the internet, explore the history of VPC and other similar approaches around the world, do a deep dive into the contours of VPC itself, identify challenges associated with VPC, and consider some possible solutions. 

Although VPC requirements have enabled millions of parents to better understand and vet their children’s online playgrounds, the VPC framework presents real challenges for young people and their guardians. The VPC process can:

Let’s Solve This!

This report identifies possible solutions that are worth further discussion. These include:

This report is intended to help identify the challenges raised by VPC and determine what the future of parental consent could be. It is also an invitation for us to find a solution together. Let’s explore the future of play!