Member companies must agree to abide by the Program Requirements. The Program Requirements are a set of guidelines that regulate the way member companies collect, use and disclose personal information from children 12 years old and under. By following the Program Requirements, visitors to websites operated by a member company are assured that:
Notice will be provided to the child's parent about the website’s information practices and prior verifiable consent will be obtained before collecting personal information from children;
The child's parent will be given the choice to consent to the collection and use of their child's personal information for internal use by the website, and the parent will be given the opportunity to elect not to have their child's personal information disclosed to third parties;
The parent will be provided with access to their child's personal information, and given the ability to review and/or delete the information and opt-out of the future collection or use of the information;
The age information on the registration form must be asked in a neutral manner that does not invite falsification. Members must employ temporary or permanent cookies to prevent children from back-buttoning to change their age in order to circumvent the parental consent requirement or obtain access to the site;
The child's participation in a game, the offering of a prize, or another activity will not be conditioned on the child's disclosure of more personal information than is reasonably necessary for the activity; and
Member companies will maintain the confidentiality, security, and integrity of the personal information they collect from children.
Integrity Membership Seal of Approval and Click-to-Verify Mark
Visitors to websites that are members in the Children’s Privacy Compliance Program can verify such membership by using the "click to verify" mark (“Verify Mark”). Each Verify Mark is linked to a verification page on a secure Aristotle server. The verification page allows parents to verify that the website is authorized to display the Integrity Membership Seal of Approval and the Verify Mark, and is in full compliance with the Program Requirements.
Compliance Advancement Team
Compliance monitoring is a central part of the entire Children’s Privacy Compliance Program and includes the following components: initial and annual self-evaluation of a member company’s website; quarterly and periodic, unannounced monitoring reviews of the member company website; and community monitoring reviews.
Third, all member companies must provide the parent and child with a reasonable and effective means to submit complaints that they may have about the member company information practices. The Children’s Privacy Compliance Program also offers the parent and child the opportunity to submit complaints about any member company website directly to the Children’s Privacy Compliance Program. A representative of the Children’s Privacy Compliance Program handles all complaints immediately. The Children’s Privacy Compliance Program maintains a record for three (3) years of all complaints received by the Children’s Privacy Compliance Program, any investigation conducted by Aristotle into the alleged violation of the Program Requirements, and the outcome of such investigation.
Member companies must provide the parent and the child with a means to submit questions or complaints that they may have about a member company’s information practices. If the parent or child is not satisfied with the response they receive from the member company, the Children’s Privacy Compliance Dispute Resolution Program offers parents assistance with resolving those complaints. Such assistance may include contacting the member company directly to investigate the complaint and finding a resolution of the parent’s or child's concern or requiring a representative of the member company to participate in the Children’s Privacy Compliance Program’s alternative dispute resolution services. In both cases, a trained member of the Children’s Privacy Compliance Program staff administers the process.