Understanding COPPA and Its Relevance to Advertising

The Children’s Online Privacy Protection Act (COPPA) sets clear rules about how personal information from children is collected and used online. For advertisers and publishers, COPPA isn’t just a compliance checkbox—it shapes how campaigns are designed, how data is gathered, and which technologies can be used to reach young audiences. In practice, COPPA focuses on children under 13 and requires special care when a site, app, or advertisement collects information that can identify a child or track their online behavior. The goal is to minimize risk for kids while ensuring parents know what data is being collected and for what purpose.

When COPPA Applies to Advertising Technology

Advertising technology is a broad ecosystem that includes ad networks, exchanges, demand-side platforms (DSPs), supply-side platforms (SSPs), and analytics tools. If any component collects information that falls under COPPA’s definitions from a user who is under 13, the activity is regulated. This often means that third-party pixels, cookies, device identifiers, or offline identifiers must be considered in terms of consent and disclosure. If your site or app is directed to children or your data practices make you knowable to be directed to children, COPPA applies more strictly. In short, the more your ad tech stack relies on collecting or sharing personal data from under-13 users, the more careful you must be with consent, data minimization, and parental notice.

Key Requirements for Compliance

• Determine directedness: Assess whether your product or platform is “directed to children” or knowingly collects information from children under 13. The criteria hinge on subject matter, language, imagery, and the audience you are likely to reach.
• Obtain verifiable parental consent when needed: If you collect PII (personal information) from a child under 13, you must obtain verifiable parental consent before collecting, using, or sharing that data. Verifiable consent means the parent has to prove their identity or control over the account with a trusted method.
• Limit data collection: Practice data minimization. Only collect information that is essential for the explicit purpose disclosed to parents, and avoid gathering sensitive data unless it’s truly necessary and consented.
• Clear privacy notices: Your privacy policy should clearly describe what data is collected, how it is used (including ad targeting), with whom it is shared (including third parties), and how parents can exercise rights such as review, deletion, or withdrawal of consent.
• Parental controls and opt-out options: Provide straightforward ways for parents to withdraw consent or restrict data collection, including options related to advertising practices and data sharing with third parties.
• Data retention and deletion: Define retention periods and implement processes to delete or anonymize data when it’s no longer needed for the purpose stated to parents.
• Third-party governance: Ensure that any partners in your ad tech stack (advertisers, networks, trackers) are aware of COPPA and commit to compatible practices, including not collecting or processing PII from under-13 users without consent where required.
• Safe harbor considerations: If you participate in COPPA Safe Harbor programs, make sure your practices align with the program requirements and that you document compliance accordingly.

Practical Steps for Advertisers and Publishers

1. Conduct a data flow audit. Map out every touchpoint where a user interacts with your site or app, including ads, analytics, and consent screens. Identify where data from under-13 users could be collected or shared with third parties.
2. Apply age screening appropriately. If you cannot verify parental consent, consider age gates or restricting features that involve data collection for younger users. Avoid relying solely on inferred age without verification for COPPA-sensitive scenarios.
3. Shift toward contextual advertising for younger audiences. Behavioral or interest-based targeting based on user profiles is often restricted for under-13 users unless parental consent is obtained. Contextual targeting uses the content of the page rather than user data, which is more COPPA-friendly for kids.
4. Review your privacy policy and disclosures. Make sure you state that ads may be served by third parties and that those parties may collect data under their own policies. Be explicit about data practices for children and how parents can exercise their rights.
5. Vet third-party partners. Require contracts or data protection agreements with ad networks and analytics providers that align with COPPA rules. Ask partners to demonstrate how they handle under-13 data, what data they collect, and how long they retain it.
6. Implement robust consent records. If parental consent is required, maintain records showing that consent was obtained, when, and by whom. Include options for parents to review, update, or revoke consent.
7. Provide easy-to-use opt-out mechanisms. Make it simple for parents to opt out of data collection, including ad tracking and sharing. Document how opt-outs affect the user experience and data flows.
8. Prepare for enforcement and audits. Keep a clear log of your data practices, decisions, and changes to your consent framework. Be ready to demonstrate compliance if regulators request information.

Contextual Targeting vs. Behavioral Data for Kids

For audiences that include children, contextual targeting—advertising delivered based on the content of the page (topic, category, or page context)—is generally safer under COPPA than behavioral targeting that relies on tracking data. When you avoid parsing or storing unique identifiers tied to a child’s online behavior, you reduce the risk of noncompliant data collection. If you must collect data for any purpose, ensure you adhere to parental consent requirements and privacy disclosures. When in doubt, favor privacy-preserving ad formats and non-identifying data signals to minimize risk while still delivering relevant content.

What About Safe Harbor and Third-Party Partners?

COPPA Safe Harbor programs exist to streamline compliance for certain types of data collection and processing. Participation in a recognized Safe Harbor can help validate your practices and provide a framework for consent management, data handling, and contractual protections with partners. If you work with multiple ad tech vendors, consider enrolling in an appropriate Safe Harbor program or implementing a robust data processing agreement that codifies consent requirements, data minimization, retention limits, and deletion rights for parental controls. Always document how Safe Harbor participation affects your obligations in your privacy notices.

Audits, Documentation, and Records

Regular internal audits are essential. Review the data you collect from users, confirm what is shared with third parties, and verify that all notices reflect current practices. Keep documentation of consent when it is required and maintain records of changes to your data practices. If regulators ever request information, you’ll want a clear trail showing how you determine whether COPPA applies, how you obtain consent, and how you manage data in your ad ecosystem.

Best Practices for Google SEO and COPPA Compliance

From an SEO and user experience perspective, write content that clearly communicates your data practices to both parents and guardians and to the broader audience. Use simple, direct language in privacy notices and consent flows. Structure content with accessible headings and scannable paragraphs, which helps signal trustworthiness to both users and search engines. For pages directed at families, emphasize safety, transparency, and control. On technical pages, describe your data flows and consent mechanisms in a way that is easy to verify. This approach improves user trust and aligns with Google’s emphasis on user-first content and high-quality, transparent information.

Conclusion

Advertising in a world shaped by COPPA requires a careful balance between effective monetization and protecting children’s privacy. By clearly identifying when COPPA applies, obtaining verifiable parental consent when needed, minimizing data collection, and maintaining transparent disclosures, advertisers and publishers can navigate the complexities of online ads without compromising trust. Emphasizing contextual targeting for younger audiences, strengthening data governance, and partnering with responsible platforms will help you meet regulatory expectations while sustaining a responsible and sustainable advertising strategy.