Smart Toys and the Children's Online Privacy Protection Act of 1998 [January 8, 2018] [open pdf - 300KB]
"A growing number of devices in American households, including televisions, appliances, security systems, and heating and cooling devices, rely on Internet connectivity to perform a range of functions. And the 'Internet of Things' includes a growing number of products primarily used by children, including 'smart toys.' In the 1980's, the popular Teddy Ruxpin bear 'talked' to children by way of a tape player hidden inside. Today, children may have real-time two-way 'conversations' with their smart toys. Sensors, mics, cameras, storage devices, speech recognition technology, Internet-connectivity, and GPS [Global Positioning System] are used to tailor the toy's behaviors based on the child's interactions. Some more sophisticated smart toys may record a child's voice on an audio file, convert the audio to text, query a searchable database, and return an appropriate voice response back to the child. But smart toys' use of Internet-connectivity potentially to collect children's personal information may require the toys' makers to take certain steps to comply with the Children's Online Privacy Protection Act of 1998 (COPPA) and its implementing rules and requirements."
CRS Legal Sidebar, LSB10051
Federation of American Scientists: http://www.fas.org/sgp/crs/index.html