COPPA Consent for AI Training
Tags: Regulatory
TL;DR
- The FTC updated COPPA to address training AI systems on children’s data.
- Verifiable parental consent is now required before using children’s data to train AI.
- COPPA enforcement remains an agency priority.
Why it matters for HK marketers: If your campaigns or vendors touch U.S. children’s data, training use without parental consent is a clear red line.
What changed
- Training explicitly covered: AI model training on children’s data falls under COPPA’s consent regime.
- Risk exposure: Vendor practices around model improvements and data retention must be scrutinized.
Operational steps
- Map any child‑directed properties, age‑gating, and data flows into AI tools.
- Ensure contracts bar training on minors’ data absent verifiable parental consent.
So what for marketers
Treat “system improvement” and “training” clauses as high‑risk in child‑adjacent campaigns. Require attestations and audit rights from AI vendors.
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