Statement on COPPA Filing

December 10, 2019

Dan Jaffe, Group Executive Vice President of Government Relations for the ANA (Association of National Advertisers), today issued the following statement in response to the Federal Trade Commission’s (FTC) request for comment on the effectiveness of the Children’s Online Privacy Protection (COPPA) Rule.

ANA applauds the FTC’s leadership on children’s privacy issues nationwide and appreciates efforts to evaluate the COPPA Rule’s adaptability to the rapid pace of technological change. However, we do believe that the Rule has proven to withstand the test of time, is effective, and only limited updates are needed to address contemporary developments and new technologies. The Commission has actively enforced the law, providing important protections in this critical area.

We encourage the Commission to ensure that any revisions to the Rule safeguard its continued ability to foster the growth and availability of online content for children.

ANA also recommends that the FTC take a position on the ways in which COPPA interacts with state laws that regulate children’s online privacy. In particular, ANA encourages the FTC to confirm that the Rule preempts state laws to the extent set forth in the COPPA statute and offer guidance to companies on overlapping laws. This action is important to avoid fragmentation of regulation in the children’s online privacy area and the development of inconsistent rules based on geographical locations.

ANA and our members are committed to prioritizing and safeguarding children’s privacy and we look forward to the continued dialogue with the FTC on this important issue.

About the ANA:
The ANA (Association of National Advertisers)'s mission is to drive growth for marketing professionals, for brands and businesses, and for the industry. Growth is foundational for all participants in the ecosystem. The ANA seeks to align those interests by leveraging the 12-point ANA Growth Agenda, which has been endorsed and embraced by the ANA Board of Directors and the Global CMO Growth Council. The ANA's membership consists of nearly 1,700 domestic and international companies, including more than 1,000 client-side marketers and nonprofit fundraisers and close to 600 marketing solutions providers (data science and technology companies, ad agencies, publishers, media companies, suppliers, and vendors). Collectively, ANA member companies represent 20,000 brands, engage 50,000 industry professionals, and invest more than $400 billion in marketing and advertising annually.