Is Echo Dot for Kids Violating Child Privacy Laws

There’s a certain tension between trying to keep kids safe on the internet while marketing internet-enabled products to kids. Take the Amazon Echo Dot Kids Edition. It’s pretty much Alexa for children, and can play age-appropriate music, answer questions, and even tell stories. Great, right?

Well, right up to the point where it is allegedly recording and storing conversation data from children, even after parents try to delete it. That’s according to a complaint filed with the Federal Trade Commission last week.

Commercials, a Complaint, and COPPA

“The Echo Dot Kids Edition records children’s voices any time it hears the wake word, and it stores these recordings in the cloud unless or until a parent deletes them,” according to the FTC complaint filed by Campaign for a Commercial-Free Childhood and other child privacy advocates. “Amazon also uses persistent identifiers to track how a child uses Echo and can use that information to recommend other content that the child might enjoy. Amazon may collect other types of personal information when children ask the Echo to remember something, or when a kid skill solicits an open ended communication from a child.”

All of this puts the Echo Dot Kids Edition within the purview of the Children’s Online Privacy Protection Act, or COPPA, a federal law prohibiting web sites from collecting personal information from children under the age of 13 without parental permission. Under COPPA it must:

  1. Post a clear and comprehensive privacy policy on their website describing their information practices for children’s personal information;
  2. Provide direct notice to parents and obtain verifiable parental consent, with limited exceptions, before collecting personal information from children;
  3. Give parents the choice of consenting to the operator’s collection and internal use of a child’s information, but prohibiting the operator from disclosing that information to third parties;
  4. Provide parents access to their child’s personal information to review and/or have the information deleted;
  5. Give parents the opportunity to prevent further use or online collection of a child’s personal information; and
  6. Maintain the confidentiality, security, and integrity of information they collect from children

“Woefully Deficient,” “Inadequate,” “Unduly Burdensome”

According to the complaint, Amazon’s direct notice to parents and its online Children’s Privacy Disclosure are “woefully deficient,” fails to give notice and obtain parental consent for information collected by third parties, has an “inadequate” system for obtaining parental consent, and “does not necessarily delete all of the child’s personal information … even when parents make an effort to delete some or all of the recordings of their child.”

Not so great, right? The complaint (along with several U.S. senators) are asking the FTC to investigate the claims and determine if the Dot Kid’s Edition is violating COPPA. If you’re worried about an internet-enabled device or app harvesting your child’s personal information, contact a local consumer protection attorney.

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