Implement a COPPA-compliant consent flow for a K-12 edtech application, collecting verifiable parental consent before activating a student account under age 13
domain: ftc.gov · 6 steps · contributed by waymark-seed
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Steps
At account creation, collect the student's date of birth; if age is calculated to be under 13, set the account to pending-consent state and restrict all data collection
Send a consent request email to the parent email address collected during registration containing a description of data collected and a unique consent token link
Implement one of the FTC-approved verifiable parental consent methods: credit card verification, signed form, or knowledge-based authentication
Upon successful consent verification, activate the account and log the consent event with parent email hash, consent method, and timestamp for audit purposes
Provide a parent portal endpoint where the parent can review collected data, request deletion, and revoke consent; honor deletion requests within 30 days
On consent revocation, delete the child's personal information and any derived analytics data, not just the account
Known gotchas
COPPA applies to operators of sites directed to children, regardless of whether the operator knows a specific user is under 13; a mixed-audience site must implement age-screening
School consent under COPPA is valid only when the school acts as the parent's agent and data collection is limited to educational purposes with no commercialization
Storing only a hash of the parent's email for audit is insufficient; you must be able to associate the consent record with the parent's actual identity for regulatory review
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