FTC Approval of CARU Safe Harbor Program

Date: Mar 22, 2001

On January 26, 2001, the Federal Trade Commission (FTC) approved the application of the Children’s Advertising Review Unit of the Council of Better Business Bureaus (CARU) safe harbor program.  This program was developed to implement the provisions of the Children’s Online Privacy Protection Rule (COPPA), effective in April 21, 2000, and satisfies the self-regulatory guidelines established by the commission, namely:

  • Providing the same or greater protections as the rule.

  • Creating a mandatory independent compliance mechanism.

  • Providing compliance incentives.

The CARU program includes a compliance checklist and requires 1) an initial self-assessment (and attestation by an officer of the company), 2) an independent assessment of the participant’s web page by the CARU staff, and, 3) continued compliance reviews.  Annual updated self-assessment forms are required as well as descriptions of any material changes to the web site.  Participants in the program submit to the self-regulatory process of the National Advertising Division/CARU/National Advertising Review Board. 

For additional information, please contact Sheila A. Millar at (202) 434-4143 or via email at millar@khlaw.com.