The FTC released a statement by Chairman Ferguson, joined by Commissioners Holyoak and Meador, regarding the enforcement action against Disney Worldwide Services for alleged violations of the Children's Online Privacy Protection Act (COPPA). The statement addresses the case involving children's privacy protections.
In-house legal teams should review all agreements involving the collection or use of data from children under 13, including customer-facing terms of service, privacy policies, vendor contracts (especially with ad-tech or analytics providers), and any data processing agreements. Focus on clauses governing consent mechanisms (ensuring they are verifiable and parental), data collection purposes, data sharing with third parties (particularly for advertising), data retention and deletion policies for minors' data, and advertising practices targeting children. Contracts may need amendments to explicitly incorporate COPPA requirements, restrict profiling of children, mandate clear parental consent flows, limit data retention to the necessary period, and prohibit unauthorized data sharing. Ensure all marketing, analytics, and platform agreements with services potentially accessed by children contain robust COPPA-compliant provisions.
Entity
Disney Worldwide Services
Also known as: Disney
Industry
Media & EntertainmentOfficial Press Release
https://www.ftc.gov/legal-library/browse/cases-proceedings/public-statements/statement-chairman-andrew-n-ferguson-joined-commissioner-melissa-holyoak-commissioner-mark-r-meador-re-united-states-v-disney-worldwide-servs-et-al
2025.09.02 2123075 disney statement ferguson holyoak meador
https://www.ftc.gov/system/files/ftc_gov/pdf/2025.09.02-2123075-disney-statement-ferguson-holyoak-meador.pdf
Federal Trade Commission Enforcement Page
https://www.ftc.gov/enforcement
"Disney Worldwide Servs."
"Children's Online Privacy Protection Act (COPPA)"
"Children's Online Privacy Protection Act (COPPA)"
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