1. I operate a moderated web site that is directed to kiddies and I also prescreen all children’s submissions to be able to delete information that is personal before postings get real time.
Yes. The amended Rule considers pictures, videos, and sound tracks which contain a child’s image or sound to be information that is personal. Which means operators covered by COPPA must either (i) prescreen and delete from children’s submissions any photos, videos, or sound tracks of by themselves or any other kiddies or (ii), first give moms and dads notice and get their permission just before allowing young ones to upload any pictures, videos, or sound tracks of by themselves or any other kiddies.