“Won’t Somebody Think of the Children?” Examining COPPA Compliance at Scale

“Won’t Somebody Think of the Children?” Examining COPPA Compliance at Scale – Irwin Reyes, Amit Elazari Bar On


We present a scalable dynamic analysis framework that allows for the automatic evaluationdomain of the privacy behaviors of Android apps. We use our system to analyze mobile apps’ compliance with the Children’s Online Privacy Protection Act (COPPA), one of the few stringent privacy laws in the U.S. Based on our automated analysis of 5,855 of the most popular free children’s apps, we found that a majority are potentially in violation of COPPA, mainly due to their use of third-party SDKs. While many of these SDKs offer configuration options to respect COPPA by disabling tracking and behavioral advertising, our data suggest that a majority of apps either do not make use of these options or incorrectly propagate them across mediation SDKs. Worse, we observed that 19% of children’s apps collect identifiers or other personally identifiable information (PII) via SDKs whose terms of service outright prohibit their use in child-directed apps. Finally, we show that efforts by Google to limit tracking through the use of a resettable advertising ID have had little success: of the 3,454 apps that share the resettable ID with advertisers, 66% transmit other, non-resettable, persistent identifiers as well, negating any intended privacy-preserving properties of the advertising ID.


Irwin is a researcher in the Usable Security and Privacy Group at the International Computer Science Institute (ICSI) affiliated with the University of California at Berkeley. He earned Bachelor’s and Master’s degrees from the University of Virginia in 2009 and 2011, respectively. Irwin has held positions developing ballistic missile defense systems at the Johns Hopkins University Applied Physics Laboratory and applying usable security concepts to commercial products at Dell. His research interests include measuring the privacy risks of everyday consumer products, user perceptions of security issues, and the online advertising ecosystem.

Amit is a doctoral law candidate at UC Berkeley School of Law and a Berkeley Center for Long-Term Cybersecurity Grantee. Her work has been published in leading technology law journals, presented in conferences such as RSA, USENIX Enigma, BsidesLV, BsidesSF, DEF CON-Skytalks and Black Hat, and featured in leading news sites such as the Wall Street Journal, Washington Post, The Guardian and the Verge. Additionally, Amit teaches at UC Berkeley’s School of Information Master of Information and Cybersecurity (MICS) program and serves as the submissions editor of BTLJ, the world’s leading Tech Law Journal. On 2018, Amit was granted a CLTC grant for her work on private ordering regulating information security.