COPPA Safe Harbor Services

As a part of CARU’s mission to help companies comply with the Children’s Online Privacy Protection Act (COPPA) and properly address the collection and retention of children’s data in an online environment, CARU provides guidance to companies on how best to comply with COPPA and the CARU Guidelines. Program participants who adhere to CARU’s Guidelines are deemed in compliance with COPPA and essentially insulated from enforcement actions by the Federal Trade Commission (FTC). 



Our Services

We want to help your company achieve its business goals while ensuring compliance with CARU’s Guidelines and the COPPA requirements. CARU will support your organization to achieve fulfillment of the program requirements by providing the following services.  


These a la carte items are available to CARU Supporters at a 20 percent discount. For individual pricing and fees for each of these services, or package discount options, please contact us


  • Comprehensive Audits – A comprehensive review of any “product”, i.e. website, mobile app, platform, or connected device/toy (“IoT”) to evaluate your data collection practices for compliance with relevant standards and laws, including:


  • U.S. state and federal laws including but not limited to COPPA, CaCPA, CAN-SPAM 


  • CARU’s Guidelines


  • Canada’s PIPEDA and CASL (anti-SPAM) laws


  • Data security/breach laws 


  • Complex Advertising Guidance – Guidance on your company’s data collection practices as they related to complex but common data collection practices including sweepstakes/contest rules and SMS/MMS campaigns. 


  • Data Tracking Assessment – Thorough review of your product to vet all data collection, including first- and third-party trackers, including applicable data collection issues/practices of online/digital advertisements, APIs, plugins, third-party vendors (including but not limited to credit card processors, analytics providers, and ad networks) as well as embedded video content.


  • Review/Reconciliation of Privacy Documents – Review of your privacy policy, terms of service, and/or EULAs to ensure necessary requirements are met as pertaining to targeting a child audience (directly or indirectly), including implementation of short-form privacy policies and upfront/just-in-time consumer notices.


  • Findings Assessment – A written assessment of all issues found by CARU, as it relates to targeting children (directly or indirectly), as well as clear recommendations and specific direction on next steps to achieve compliance with program requirements and applicable laws.


  • Developer Checklists – Facilitate privacy by design at the outset of product development with a checklist for your developers, tailored upon request and consultation.


  • GDPR Guidance/Consultation – Hands-on support for top-level issues and, where applicable, a referral to our in-house BBB EU Privacy Shield team to assist you with further compliance.


  • Ongoing Guidance – Access to our lawyers for ongoing counseling via email or phone with fast turnaround and sensitivity to your deadlines. This includes continued review and advice when product content and/or data collection practices change.


  • Regular Monitoring – Ongoing reviews of your products to ensure you remain in compliance, alerting you to changes or issues outside of regular compliance reporting periods.


  • Educational Access – Access to quarterly webinars, conferences, guidance and resources, client bulletins, and on-site staff visits with privacy training upon request.


  • Advertising Pre-screen Review – Safe Harbor membership includes one pre-screen, which covers review of scripts, storyboards, “rough cut” draft and/or final edit of advertisements with live action, moving frames, with or without audio (valued at $1,000). Unlimited advertising pre-screen reviews are available to CARU supporters. 



Fees for Safe Harbor Services 

Fee schedule is available upon request. CARU Supporters receive a 20 percent discount. 


Email Us to learn more about CARU's COPPA Safe Harbor Program and how your organization can become a CARU Supporter.