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The Privacy Advisor | Imperium Wins FTC Approval for COPPA-Compliant Authentication Related reading: Advocacy Group Alleges Site Violates COPPA


Fraud prevention and identity validation solutions provider Imperium was recently granted a patent for its ChildGuardOnline parental-verification service. It also recently gained Federal Trade Commission (FTC) approval for its knowledge-based authentication method.

Marshall Harrison, founder and CEO of Imperium, said that ChildGuardOnline was created in anticipation of changes to the Children’s Online Privacy Protection Act (COPPA).

“We became aware a couple of years ago that the FTC was going to be strengthening COPPA with regard to what types of data would be covered, as well as the type of verifiable parental consent that would be accepted by the FTC in connection with COPPA,” he said. “We developed ChildGuardOnline specifically to anticipate the new regulations that the FTC would be announcing.”  

ChildGuardOnline uses a combination of modern technologies, in partnership with Imperium’s anti-fraud methodological expertise, to accurately verify parental consent.

“Using this service and these tools is much more effective than just getting a Safe Harbor certificate,” Harrison said. “Although a Safe Harbor certificate has value, it doesn’t actually deliver verifiable parental consent.”

ChildGuardOnline fills that gap, he said. The knowledge-based method gives companies the ability to ask a person a number of dynamically generated, challenge/response questions to establish valid identification.

Gaining FTC approval was a rigorous process, Harrison said.

“The FTC already allows certain methodology within (COPPA) itself. We developed a new methodology, and the FTC had questions about it, which required many conversations with them,” Harrison said. “They were eventually satisfied that this was not only a new method but that it was efficacious.”

The service offers several COPPA-compliant techniques to obtain the necessary consent and to validate a parent’s ID, including submitted address and discovered geolocation data, correlation of the number of children per parent, number of sites approved per parent and child and the last four digits of Social Security numbers. A parent portal allows parents to instantly approve and proactively manage the websites they have authorized for their child’s use.

Harrison said the new technology will save companies both time and money because they avoid the administrative costs associated with other identification methods, like the email-plus method.

“We think of email as being free, and it is on the margin free to send that email. But, email-plus has to be monitored, looked after and audited,” Harrison said. “The largest potential cost is that the FTC will fine the company $16,000 per child for noncompliance, which adds up in a hurry, and even without the fines, there is reputational damage.”


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