What if, despite my most careful efforts, I mistakenly give out a child’s personal information to someone who isn’t that child’s parent or guardian?
Reasonable methods for verifying that a person seeking access to a childs information is the parent, taking into account available technology, include: providing a mailing address or fax number for the parent to make the request in writing; providing a toll-free number staffed by trained personnel for a parent to call; using a credit card in connection with a transaction; using digital signatures; using an email accompanied by a PIN or password obtained through one of the above methods; or submission of a drivers license. See Statement of Basis and Purpose, 64 Fed. Reg. 59888, et seq., available at www.ftc.gov/os/1999/10/64fr59888.pdf, p. 59905. Under the Rule, if you act in good faith and follow reasonable procedures to verify that the requestor is the parent, then you will not be liable under any federal or state law if you mistakenly release a childs personal information to a person other than the parent. See 16 C.F.R. 312.6(b).
Related Questions
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