In 2020, after the textbook for this course was published, the company HyperBeard, which develops and markets computer and phone games for kids, agreed to settle a COPPA complaint from the Federal Trade Commission for $4M. HyperBeard was accused of not safeguarding the information from children under the age of 13 that was collected through HyperBeard’s apps and website. HyperBeard had posted a disclaimer on all their apps stating the games were not intended for children under the age of 13. The FTC looked at the games and decided that they were aimed at children younger than 13. HyperBeard allowed third-party advertisers to collect data on the users of the games in order to target advertising to them. Targeted advertising makes the Internet go, but COPPA says it is not allowed with children under 13 without parental consent.
There are a number of problems highlighted in this case. How can a business with a web presence really know how old its customers are? HyperBeard’s disclaimers did nothing for the company; should warnings and advisories provide some protection for companies? There did not appear to be a concrete set of rules established to guide the decisions of the FTC in this case; their judgements appeared very subjective, much like the 1964 Supreme Court ruling on pornography, “you know it when you see it.” How can companies establish cybersecurity programs with proper privacy protections for children under such vague guidelines? Do you think HyperBeard was the only company violating the rules?
Re-read the article: Tracking Kids Through Your App? Think Again.
Assume you work in a company that makes games for kids, and you were assigned to study the HyperBeard case by your board of directors in order to recommend policies and controls to safeguard your company from losses due to similar actions.
Write a paper to convince your leadership to adopt your recommendations. The length of the paper is not specified; you will be graded on how thoroughly you treat each section of the assignment and the quality of your writing. Your paper will be graded on your description of the facts of the case, your legal analysis, the quality of your recommendations to avoid similar losses, and writing that is clear, concise, and correct. Multiple quality sources with APA citations are expected. For APA and Standard Paper Guidelines, see the “Course Resources” link in the left navigation area.