COPPA Compliance Checklist for EdTech and Gaming Sites

EdTech platforms and children’s or family-oriented gaming sites carry structurally higher COPPA exposure than almost any other category, they’re often explicitly child-directed, frequently have school-based deployment (which raises its own consent-delegation questions), and commonly integrate third-party ad, analytics, and social features by default. This checklist covers the areas worth auditing first.

1. Confirm your actual COPPA classification

Don’t assume, verify. Run your site or app against the FTC’s “directed to children” factors covered in our classification guide, and if you serve a genuinely mixed audience, confirm your age-screen implementation actually gates data collection rather than running in parallel with it.

2. Audit every third-party script against child-directed pages

Ad networks, analytics tools, social widgets, and session-recording scripts are the most common source of unintended COPPA exposure, covered in depth in our third-party tracker guide. For edtech and gaming specifically, watch for: ad SDKs bundled into mobile builds by default, analytics tools added for engagement metrics without a children’s-data review, and third-party login or social-sharing features that set cross-site identifiers.

3. Handle school-based consent correctly

EdTech deployed through schools has a specific FTC-recognized consent path: a school can consent on behalf of parents for ed-tech used strictly for educational purposes, within the scope of the school’s relationship with the vendor. This exception is narrower than it’s sometimes assumed to be, it covers data used for the educational purposes the school authorized, not a blanket permission for any use, including behavioral advertising or unrelated data sales.

4. Verify your parental consent mechanism matches your actual data use

If your app discloses data to third parties (ad networks, analytics platforms outside a narrow internal-operations exception), confirm your consent mechanism is one of the methods actually suited to that level of disclosure, not “email plus,” which is limited to internal-use-only scenarios. See our parental consent methods guide for the full list.

5. Check in-game/in-app purchase and chat features specifically

Two features common in gaming products carry outsized COPPA risk: in-app purchases that could constitute collecting payment-linked personal information from a child without consent, and open chat or messaging features that let children share personal information with other users or the platform, both of which need to be evaluated as their own data collection points, not just the signup flow.

6. Review your privacy policy’s COPPA-specific sections

Confirm the specific required disclosures, data minimization statement, parental rights, and direct parental notice, are actually present, not just implied by a general privacy policy. Our COPPA privacy policy guide covers the full required list.

7. Document everything

Given that COPPA penalties scale per affected child, a documented, defensible compliance process, consent records, vendor reviews, age-screen logs, matters more for higher-traffic platforms than for almost any other compliance area covered on this site. Treat documentation as part of the compliance work itself, not an afterthought.

The bottom line

EdTech and gaming platforms sit at the intersection of the factors that create the most COPPA exposure: genuine child-directed audiences, heavy third-party SDK integration, and consent mechanisms (school-based or parental) that are easy to implement incorrectly. Working through this checklist deliberately, rather than assuming a general privacy compliance program covers it, is worth the time given how directly this category maps onto COPPA’s core concerns.

This guide is educational and not legal advice. For your specific situation, consult a privacy attorney.