COPPA Violation Cases: Lessons for Compliance and Risk Mitigation

The Children’s Online Privacy Protection Act (COPPA) governs how websites and online services collect personal information from children under 13. For platforms that serve a broad audience, COPPA creates a clear boundary between normal user data practices and those that require parental involvement. Over the years, high‑profile enforcement actions have underscored three core themes: obtaining verifiable parental consent, limiting data collection from children, and maintaining transparent privacy practices. Reading these COPPA violation cases helps online operators understand where risk lives and how to build durable compliance into product design.

What COPPA demands and why it matters

COPPA is designed to shield young users from unintended data collection and targeted advertising. In practice, this means that any service likely to collect personal information from a child under 13 must provide a clear privacy policy, obtain verifiable parental consent before collecting data, and use data only in ways permitted by the parent. For platforms with user-generated content, features such as comments, profiles, or personalized ads can trigger COPPA obligations even if they are optional for adults. The consequence of noncompliance is not just a one‑time fine; it can involve ongoing monitoring, corrective actions, and reputational harm that linger long after a case is closed.

Notable COPPA enforcement actions

Two cases in particular have become the touchpoints that industry players study when assessing COPPA risk and enforcement readiness. They illustrate how misuse of data, misleading disclosures, or lax consent practices can lead to substantial penalties and formal corrective orders.

• YouTube and Google (2019 settlement): The Federal Trade Commission (FTC) fined Google and its video platform YouTube $170 million for COPPA violations. The core issue was collecting personal data from children under 13 through personalized ads and other tracking measures without obtaining verifiable parental consent. The case also highlighted the need to separate data practices for kids and adults, especially when a service hosts user-generated content that attracts young viewers. The outcome pushed many services to rethink how they present features to child audiences and how they explain data collection in their privacy notices.
• TikTok (2019 settlement): TikTok agreed to pay $5.7 million to settle accusations that it collected personal information from children under 13 without parental consent. The enforcement action focused on account creation, data collection, and the lack of adequate parental controls. This case underscored that even platforms popular with a broad audience must assess how account creation flows, child-facing features, and third‑party data sharing align with COPPA requirements.

Beyond these headline actions, the FTC and state authorities continue to scrutinize apps, games, and kid-friendly services that operate across mobile and web ecosystems. While not every case results in a public settlement, the pattern remains consistent: data collection from children under 13 requires strong consent mechanisms, restricted data usage, and transparent disclosures that avoid misleading impressions about privacy protections.

Common patterns in COPPA violations

Several recurring patterns emerge when examining COPPA violation cases. These patterns help operators identify blind spots before they escalate into enforcement actions.

• Misleading or opaque disclosures: Privacy notices that do not clearly state how data from children will be used, shared, or retained can trigger COPPA concerns. A common fault is implying broad data use without specifically calling out child data practices.
• Inadequate consent mechanisms: When a service relies on implied consent, pre-ticked boxes, or nonverifiable parental consent for under‑13 users, COPPA risks increase. Verifiable parental consent must be collected before any child data is gathered.
• Inappropriate collection through child-oriented features: Interactive quizzes, comments, profiles, or messaging that invite young users to reveal personal information often collides with COPPA unless proper safeguards are in place.
• Data sharing and third-party integrations: Partner networks, analytics, and ad services can receive data from child accounts. If COPPA requirements are not extended to these partners, the service remains noncompliant.
• Insufficient data minimization: Collecting more data than necessary for the service increases the risk exposure under COPPA. The principle of data minimization is central to compliance.

What these cases teach about enforcement and risk management

From these COPPA violation cases, several lessons stand out for product teams, legal, and executive leadership:

• Design for consent from the start: Privacy by design means building age verification and parental consent flows into onboarding, not as a later add‑on. For services likely to attract children, a deliberate, verifiable consent process reduces future risk.
• Segment data by audience: Separate handling of child data from general user data is critical. If a platform suspects users under 13 may be present, it should implement protective defaults (e.g., limited data collection, non‑targeted ads) and clear age gating.
• Be explicit in notices: Clear, concise, and easily accessible privacy policies that describe data collection, usage, sharing, retention, and parental rights help demonstrate compliance and brand trust.
• Vet third-party partners: Ensure that any analytics, ads, or social features used on the site or app comply with COPPA. Contracts should require partners to adhere to COPPA standards and to provide verifiable evidence of compliance.
• Maintain an auditable trail: Documentation of consent records, data minimization steps, and privacy controls supports accountability during investigations or audits.

Practical steps for platform operators and developers

If you’re building or running online services with a potential child audience, these practical steps can help you align with COPPA expectations and reduce risk:

1. Map which parts of your service could collect personal information from children under 13. If child access is possible, treat that pathway with heightened privacy protections.
2. Use a consent mechanism that provides a verifiable link between the child’s account and a parent’s approval. Keep records of consent in a way that’s auditable by regulators if needed.
3. Collect only what is strictly necessary for the service’s core function. Avoid defaulting to personalized ads or cross‑site tracking for child users.
4. For younger users, consider content and feature restrictions that reduce exposure to data collection and advertising targeting.
5. Publish a dedicated COPPA section that explains what data is collected from children, how it’s used, with whom it’s shared, and how parents can exercise their rights.
6. Regularly review data flows, third-party integrations, and consent mechanisms. Train product, engineering, and marketing teams on COPPA requirements and how to recognize potential red flags.

Industry best practices that reinforce COPPA compliance

Beyond responding to enforcement actions, adopting best practices creates a safer product and a stronger brand. Consider these approaches as part of a long-term COPPA strategy:

• Establish a COPPA governance role or committee responsible for privacy for children’s data.
• Perform periodic privacy impact assessments focused on under-13 users and child-facing features.
• Coordinate with legal counsel to keep privacy notices up to date with evolving interpretations of COPPA and FTC guidance.
• Prepare an incident response plan that includes steps to suspend or modify features if a data collection risk involving children is identified.
• Communicate transparently with parents and guardians about how to exercise their rights, review collected data, and request deletion when appropriate.

Conclusion: turning COPPA lessons into practical resilience

COPPA violation cases like the YouTube and TikTok settlements show that regulators reward clear, deliberate protections for child data. They remind platform operators that parental involvement is not optional for under‑13 users, and that data minimization, visible privacy commitments, and careful third-party governance are essential. By integrating COPPA considerations into product design, data architecture, and partner practices, online services can reduce risk, protect children, and build trust with parents. The goal is not merely to avoid penalties but to create responsible experiences that respect family privacy while still delivering engaging digital products.