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FTC Removes Aristotle from COPPA Safe Harbor Program

Aristotle International, Inc.August 4, 2021Federal Trade Commission

Summary

The FTC removed Aristotle International, Inc. from its list of approved COPPA Safe Harbor programs due to insufficient monitoring of member companies' compliance with COPPA guidelines. This action prevents operators from using Aristotle's program for favorable regulatory treatment and marks the first such removal since COPPA's inception.

Remedy

Aristotle was banned from the FTC's COPPA Safe Harbor program, meaning it can no longer certify companies for compliance and operators lose the benefits of its oversight.

Ban

Contract Impact

In-house legal teams should review all vendor and customer agreements where a party represents compliance with children's privacy laws through an FTC-approved Safe Harbor program, particularly those referencing Aristotle International or similar self-regulatory organizations. Specific clauses to scrutinize include: (1) representations and warranties regarding COPPA compliance and Safe Harbor participation; (2) monitoring, audit, and enforcement obligations of the self-regulatory organization; (3) termination rights triggered if a Safe Harbor program loses FTC approval; and (4) indemnification provisions related to privacy violations. Agreements may need amendments to require alternative compliance methods (e.g., direct adherence to COPPA) and to add notification obligations if a designated Safe Harbor program is delisted. Employee agreements involving data handling of children's information should also be assessed for alignment with direct COPPA requirements.

Contract Search Terms

Safe Harbor programCOPPA compliance certificationthird-party monitoringself-regulatory organizationchildren's privacy programregulatory safe harborcompliance audit rightscertification benefits

Laws Cited

COPPACOPPA Rule

Violation Types

Entity Details

Entity

Aristotle International, Inc.

Also known as: Aristotle

Industry

Other

Official Sources

Source Evidence

Entity Name
"Aristotle International, Inc. (Aristotle)"
Laws Cited
"Children’s Online Privacy Protection Act (COPPA)"
Laws Cited
"COPPA Rule"
Violation Types
"may not have sufficiently monitored its member companies to ensure they were complying with its guidelines, as required by the COPPA Rule."

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