A homework-help website directed at children lets a child type in a question and provide an email address so the site can email a single answer back, after which the email is deleted and never used again. The site collects no other information and makes no further contact. The operator wants to know whether COPPA still forces it to obtain verifiable parental consent before this one-time email exchange. Counsel must identify the governing rule. Which assessment is correct?
- ACOPPA always requires verifiable parental consent before any collection of a child's email, so the operator must obtain consent even for this one-time reply.
- BCOPPA provides a limited exception allowing collection of a child's online contact details to respond once to a specific request, so no prior verifiable parental consent is required for this single response. Correct
- CCOPPA does not apply, because a child's email address is not online contact information and therefore is never personal information under the statute.
- DCOPPA permits the collection only if the operator first posts a notice and obtains the child's own affirmative agreement in place of parental consent.
Why A is wrong: Tempting because consent is COPPA's general rule, but the Rule carves out specific exceptions, and a one-time response to a child's own request is one of them, so the absolute framing here is wrong.
Why B is correct: Correct: the COPPA Rule includes a narrow exception permitting an operator to collect a child's online contact information solely to respond on a one-time basis to a specific request and then delete it, so prior verifiable parental consent is not required for this single email reply.
Why C is wrong: Tempting because the exception leads to no consent here, but the right reason is the one-time response exception, not that email is excluded; an email address is online contact information and is personal information under COPPA.
Why D is wrong: Tempting because a notice sounds protective, but COPPA does not let a child substitute their own agreement for parental consent, and the one-time response exception turns on the limited purpose and deletion, not on the child's consent.