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Disney Subsidiary Will Pay $3 Million for Violating Children’s Online Privacy
 A Disney subsidiary, Playdom, Inc., has agreed to pay a $3 million penalty to settle a Federal Trade Commission (FTC) charge that it violated the FTC’s Children’s Online Privacy Protection Act (COPPA) Rule by collecting and disclosing personal information from hundreds of thousands of children under age 13 without their parents’ prior consent.
This settlement is the largest civil penalty for a violation of the COPPA Rule. The COPPA Rule requires that website operators notify parents and obtain their consent before they collect, use, or disclose children’s personal information. The COPPA Rule also requires that website operators post a privacy policy that is clear, understandable, and complete.
Playdom is a leading developer of online multi-player gaming virtual worlds. At least one of them, called Pony Stars, was specifically directed to children, and others intended for a general audience also attracted significant children. The FTC complaint alleged that Playdom collected children’s ages and email addresses during registration, and then enabled children to publicly post their full names, email addresses, instant messenger IDs, and location on personal profile pages and in online community forums.
The FTC charged that Playdom’s failure to provide proper notice or obtain parents’ prior verifiable consent before collecting or disclosing children’s personal information violated the COPPA Rule. It further charged that Playdom violated the FTC Act because Playdom’s privacy policy misrepresented that it would prohibit children under 13 from posting personal information online.
In addition to the $3 million penalty, the consent decree permanently bars Playdom from violating the COPPA Rule and from misrepresenting their information practices regarding children.
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 About Cameron G. Shilling
Cam is a partner at McLane, and leads McLane’s Privacy and Data Security Group. He comes from a background of handling technology, business litigation, and employment matters, and has an active practice in New Hampshire and Massachusetts.
Cam’s expertise in data security includes managing security audits, preparing and implementing written data security policies, addressing day-to-day security issues, and investigating and remediating data security breaches. He has dealt with these issues under a range of state and federal laws, including the Gramm-Leach-Blilely Act, Health Insurance Portability and Accountability Act (HIPAA), Health Information Technology for Economic and Clinical Health Act (HITECH), Genetic Information Non-Discrimination Act (GINA), Children’s Online Privacy Protection Act (COPPA), Fair Credit Reporting Act (FCRA), Fair and Accurate Credit Transactions Act (FACTA), a number of state data security laws.
Cam’s expertise in data privacy matters includes creating and implementing information security policies, advising employers with respect to workplace privacy, advising clients with respect to social media, advising companies with respect to customer and consumer privacy, and handling claims against companies for invasion of data privacy. He has dealt with these issues under a number of state and federal laws, including the Electronic Communications Privacy Act (ECPA), Stored Communications Act (SCA), Computer Fraud and Abuse Act (CFAA), Fair Trade Commissions Act (FTC Act), Massachusetts’ Privacy Act, state Wiretap Laws, and a variety of other state laws.
Cam graduated from the Cornell Law School in 1995, Lewis & Clark Colleged in 1992, and interned for United States District Court Judge Royce C. Lamberth in Washington, D.C. He lives in Bedford, New Hampshire, with his wife and two children, and enjoys skiing, hiking and tennis.
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This entry was posted in News, Privacy and tagged Consumer Privacy, COPPA, Privacy Law. Bookmark the permalink.
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