COPPA
U.S. regulation mandating parental consent for children's online data collection
23 NYCRR 500
NY regulation for financial services cybersecurity compliance
Quick Verdict
COPPA safeguards children's online privacy via parental consent for under-13 data collection, while 23 NYCRR 500 mandates cybersecurity programs for NY financial firms. Companies adopt COPPA to avoid FTC fines; 23 NYCRR 500 for regulatory compliance and resilience.
COPPA
Children's Online Privacy Protection Act (COPPA)
Key Features
- Mandates verifiable parental consent before collecting personal info from children under 13
- Targets commercial websites, apps, IoT directed to children or with actual knowledge
- Broadly defines personal information including persistent IDs and geolocation data
- Enforced by FTC with civil penalties up to $43,792 per violation
- Grants parents rights to access, review, and delete child's data
23 NYCRR 500
23 NYCRR Part 500 Cybersecurity Regulation
Key Features
- Annual CISO/CEO dual-signature compliance certification
- 72-hour cybersecurity incident notification to NYDFS
- Phishing-resistant MFA for privileged and remote access
- Comprehensive TPSP risk management and contractual controls
- Risk-based annual penetration testing and vulnerability assessments
Detailed Analysis
A comprehensive look at the specific requirements, scope, and impact of each standard.
COPPA Details
What It Is
The Children's Online Privacy Protection Act (COPPA), enacted in 1998 and effective April 21, 2000, is a U.S. federal regulation enforced by the Federal Trade Commission (FTC). It protects children under 13 from unauthorized online personal data collection by commercial operators of websites, apps, and IoT devices. The parent-empowerment approach mandates verifiable parental consent (VPC) before collection, use, or disclosure.
Key Components
- **Core ObligationsPost privacy notices, obtain VPC (11+ methods like credit card verification, video calls), provide parental data access/review/deletion.
- **Personal InformationIncludes names, addresses, persistent identifiers (IP, device IDs), street-level geolocation, audio/video files.
- **PracticesData minimization, security, no conditioning on kids' data.
- **Compliance ModelSelf-certification or FTC-approved safe harbors (e.g., ESRB, iKeepSafe) with audits; 2013 amendments expanded scope.
Why Organizations Use It
Avoids hefty FTC penalties ($43,792/violation; YouTube $170M fine). Meets legal requirements for child-directed services, builds parental trust, reduces breach risks, supports global operations targeting U.S. kids.
Implementation Overview
Analyze audience for child appeal or actual knowledge; deploy age screens, VPC mechanisms, secure policies. Suits all sizes in edtech/gaming; no mandatory certification but safe harbor audits; ongoing via tech updates, Federal Register monitoring.
23 NYCRR 500 Details
What It Is
23 NYCRR Part 500 is the New York Department of Financial Services (NYDFS) Cybersecurity Regulation, a state-level mandate for financial entities. It establishes minimum, risk-based cybersecurity requirements to protect nonpublic information (NPI) and information systems' confidentiality, integrity, and availability. The approach centers on documented risk assessments informing program design, governance, and controls.
Key Components
- 14 core requirements including cybersecurity program (§500.2), CISO appointment (§500.4), MFA (§500.12), encryption (§500.15), TPSP oversight (§500.11), penetration testing (§500.5), and 72-hour incident notification (§500.17).
- Built on risk assessment (§500.9) as foundation; annual CISO/CEO certification with five-year record retention.
- Compliance model features phased deadlines, Class A enhanced controls, and NYDFS enforcement via consent orders.
Why Organizations Use It
Financial services firms in NY comply to avoid multimillion-dollar fines (e.g., Robinhood $30M), ensure operational resilience, and meet legal obligations for licensed entities. It reduces cyber incident risk, strengthens TPSP management, builds stakeholder trust, and aligns with NIST CSF for broader benefits.
Implementation Overview
Phased rollout (up to 24 months post-2023 amendments) involves gap analysis, asset inventory, MFA rollout, TPSP contracts, and evidence repositories. Applies to NY-licensed banks, insurers, etc.; no formal certification but annual filings and NYDFS examinations required. (178 words)
Key Differences
| Aspect | COPPA | 23 NYCRR 500 |
|---|---|---|
| Scope | Child online privacy and data collection | Financial cybersecurity program and NPI protection |
| Industry | Online services, apps targeting children under 13, global | NY financial services entities, state-specific |
| Nature | Federal privacy regulation, FTC enforced, mandatory | State cybersecurity regulation, NYDFS enforced, mandatory |
| Testing | No mandated testing, compliance audits by FTC | Annual pen testing, bi-annual vulnerability assessments |
| Penalties | $43,792 per violation, e.g. YouTube $170M | Multi-million fines, consent orders, e.g. Robinhood $30M |
Scope
Industry
Nature
Testing
Penalties
Frequently Asked Questions
Common questions about COPPA and 23 NYCRR 500
COPPA FAQ
23 NYCRR 500 FAQ
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