Your problem has had me doing research and it appears that we missed a clarification of COPPA by the FTC in 2015 that exempts schools.
So how does COPPA apply to schools? Here’s the short answer: Schools – which are usually part of the local government – don’t fall within the legal definition of who’s covered by COPPA because they aren’t commercial “operators.”
With this clarification that COPPA does not apply to CCC (we are not commercial operators), we can collect data on individuals under the age of 13.
Please inform the steering committee and add this change request into the current June release if possible.
Whew. One less law to follow.
Fantastic! Thank you Tim.
I appreciate the solution for our underage students. We do still need a way to address the CCCID creation for our other special populations as I described below.
We just want to eliminate any check on the students age. Hoping this is not a big deal.