Last week, the staff of the Federal Trade Commission (“FTC”) issued crucial reading for operators of websites, apps, plug-ins, ad networks and other online services (together, “Services”) that are subject to its recently revised rule implementing the Children’s Online Privacy Protection Act (“Rule”): a much anticipated update of its COPPA FAQs.1 Many of the 92 FAQs mirror those previously published by the staff, and most of the new FAQs draw largely from the FTC’s Statement of Basis and Purpose issued with the final revised Rule. A few things, however, are new. While they do not address all of the issues businesses are facing as they prepare to come into compliance by the revised Rule’s July 1, 2013, effective date, the FAQs provide valuable insight into how the staff interprets the revised Rule and how it thinks companies should comply.

- Highlights are below:

• The staff explains how operators should treat information that it collected prior to the revised Rule’s effective date but that did not fall within the definition of “personal information” at the time it was collected (FAQ 4)...