Campaign for a Commercial-Free Childhood, the Center for Digital Democracy, and nineteen other parent, consumer, and tech groups filed a complaint to the Federal Trade Commission (FTC) Thursday, alleging that Amazon violates the Children’s Online Privacy Protection Act (COPPA) with the Echo Dot Kids Edition.
The complaint says that the Amazon Echo Dot Kids Edition, which launched in April 2018, has inadequate measures to get parental consent, shares child data with third parties without consent, and keeps kids’ data indefinitely unless a parent goes out of their way to delete data. All of these measures are illegal under COPPA.
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“Given the popularity of Amazon’s Echo Dot Kids Edition and the device’s potential to collect vast amounts of highly sensitive information,” the complaint says, “it is critical that the FTC promptly investigate Amazon’s practices and take action to enforce the law and to protect children’s online privacy.”
Some senators and advocates have argued that kid-focused products—such as YouTube Kids, Facebook Messenger Kids, and even Amazon for Teens—need to be explicitly prevented from encouraging compulsive use in their interface. But Alexa was designed to collect and process mass-amounts of sensitive data, and the Echo Dot Kids Edition may already be violating children’s privacy law, according to the complaint.
An Amazon spokesperson told Motherboard in an email that FreeTime on Alexa—a mode on the adult Echo Dot designed for use by kids—and the Echo Dot Kids Edition are compliant with COPPA.
The Echo Dot Kids Edition, according to the complaint, has an inadequate system for getting parental consent because on the device, entering a credit or debit card number and CVV code qualifies as gaining parental consent. This can be easily bypassed by a child with intent, the complaint argues.
“COPPA lists various methods of attaining verifiable parental consent that have been approved by the FTC,” the complaint says. “Instead of using one of these methods, Amazon elects to use its own insufficient method.”
The complaint also says that Amazon doesn’t provide enough information to parents in order to give informed consent for their children. The complaint claims that Amazon keeps voice recordings of children indefinitely, which is considered “personally identifiable information” that should be deleted under COPPA. Unless a parent goes out of their way to ask Amazon to delete recordings of a child’s voice, the company will continue to store that information, the complaint says.
The complaint also alleges that the Echo Dot Kids Edition doesn’t require parental consent for data collected by third parties connected to services on the device. This applies to Amazon “kid skills”—or Echo commands that conjure up kid-specific content—which are often developed by third parties. For instance, according to Amazon, the skill “Alexa, start the SpongeBob Challenge” was developed by Nickelodeon and will lead kids to Nickelodeon content.
According to the complaint, out of the 2,077 kid skills listings in the Amazon Alexa store, 84.6 percent of them don’t link to a privacy policy. Those that do link to privacy policies, the complaint says, don’t say anything specifically about data collected using the Echo Dot Kids Edition.
The complaint also introduces the “Playdate Problem”: When a child has a playdate with a child with an Echo Dot Kids Edition, the device will record the friend’s voice and store their voice data without getting parental consent or alerting the parents.
“Even if parents somehow learn that Amazon collected personal information from their child, they would not be able to delete such information,” the complaint reads.
Lindsey Barrett, a staff attorney at Georgetown Law’s tech clinic who helped work on the FTC complaint, said in a tweet that the Echo Dot Kids Edition puts kids at risk in ways that COPPA was designed to prevent.
“COPPA is intended to empower parents to protect their children from online threats, & to limit companies from surveilling them, given kids’ particular vulnerabilities,” Barrett wrote. “Amazon is both making it harder for parents to protect their kids and breaking the law.”
