Earlier this year, Pixalate formed a Trust and Safety Advisory Board to quality check our automated COPPA Compliance methodology using a manual review process to assess whether apps are child-directed based on the factors outlined in the COPPA Rule.
In a new blog series, Pixalate is making public the results of our teachers’ manual review process for assessing child-directedness for the most popular apps. This type of public assessment has never been done before - and we hope it brings transparency for app developers, the digital ad ecosystem, policymakers, and privacy advocates.
This post serves as an FAQ about the Trust and Safety Advisory Board, its manual review process, and the blog series.
About the author: Allison Lefrak is Pixalate’s SVP of Public Policy, Ads Privacy, and COPPA Compliance. She previously worked at the Federal Trade Commission (FTC). She was a Senior Attorney and the Identity Theft Program Manager in the Division of Privacy and Identity Protection which is the division charged with enforcing COPPA. She worked on a number of COPPA enforcement actions including the settlement with Musical.ly (now known as TikTok).
Table of Contents
Provide transparency into Pixalate’s manual review methodology and further educate the ad tech community and app developers to enhance their COPPA compliance practices.
Google and Apple fail to provide a turn-key solution for determining if an app, in their respective app stores, is child-directed. Their content ratings do not directly correlate with whether an app is targeting children under 13, and they continue to fall short of scalable solutions for identifying child-directed apps according to the COPPA Rule.
Manual review means that a human being reviews an app to assess whether or not it is targeting children under 13. This is important to COPPA compliance because the factors under the Rule are subjective.
There are two categories of online services under COPPA: directed to children and general audience. Mixed audience apps are a subset of the child-directed category, not a category unto itself.
Classifying a service as child-directed requires consideration of the ten factors set forth in the COPPA Rule. The list below contains the factors and an explanation of each one.
Pixalate provides compliance solutions for children’s online privacy by assessing mobile apps for child directedness under COPPA. This enables ad tech companies, app developers, and others to identify apps targeting children under 13, the first step in mitigating COPPA compliance. Common Sense Media reviews media that appeals to kids, and evaluates it based on age appropriateness. Their goal is to inform parents so they better understand what kids can handle at every age. Common Sense Media does not provide solutions for complying with online privacy laws.
In each blog post, one of our Pixalate Trust & Safety Advisory Board teachers will highlight their assessment of the most popular apps that they manually analyzed for child-directedness based on the factors in the COPPA Rule.
The teacher will indicate the factors they relied upon in their assessment using the 10 factors shown below that reflect the ten child-directed factors in the COPPA Rule. You can read more about these factors above.
Note: Not every factor comes into play when analyzing an app for child directedness. For example, a coloring app may not have any celebrities or music. Therefore, when our educators evaluate the app, those factors will not be featured as an influential part of their analysis.
While an app may not be featured in this blog series, you can view Pixalate’s assessment of any app in the Google Play or Apple App store by visiting the Pixalate Media Ratings Terminal.
Pixalate’s Trust & Safety Advisory Board is composed of teachers who have first hand experience working with children under 13. The child-directed factors in the COPPA Rule entail knowing what children under 13 would be attracted to when it comes to online services including mobile apps. Teachers are particularly well-suited to apply these subjective factors given their experience with children and technology in the classroom.
Disclaimer
This blog post published by Pixalate is available for informational purposes only and is not considered legal advice. By viewing this blog post, the reader understands and agrees that there is no attorney-client relationship between the reader and the blog publisher. The blog should not be used as a substitute for legal advice from a licensed professional attorney in the applicable jurisdiction(s), and readers are urged to consult their own legal counsel on any specific legal questions concerning any specific situation. The content of this blog post reflects Pixalate's opinions with respect to factors that Pixalate believes may be useful to the digital media industry. Pixalate's opinions are just that, opinions, which means that they are neither facts nor guarantees; and this blog post is not intended to impugn the standing or reputation of any entity, person or app, but instead, to report findings pertaining to mobile and Connected TV (CTV) apps.
