Online Talent Search Company Settles FTC Allegations Regarding Inappropriate Collection of Children’s Information

A web-based talent search company Prime Sites, Inc. (d/b/a Explore Talent) has agreed to pay $235,000 in civil penalties to settle Federal Trade Commission charges that it failed to obtain parental consent before collecting personal information from children, and that it misled consumers about the benefits of its premium paid services. Explore Talent marketed itself to aspiring actors, models, and other artists as a way to search for information about upcoming auditions, casting calls, and other professional opportunities. According to the complaint, the site required users, including children under age 13, to submit personal information such as their names, email addresses, telephone numbers and mailing address in order to create a free account or a premium, paid account. The company included some of this information in user profiles that were publicly available and searchable on the company’s website. In the settlement agreement Explore Talent has agreed to comply with COPPA in the future, pay a $500,000 civil penalty (suspended upon payment of $235,000), and delete the information previously collected from children (subject to an exception to the extent the information is requested by a government agency or required by law, regulation, or court order). The Settlement Agreement is also interesting it the expanded definition of personal information. (See Settlement Agreement ¶12, pgs 5-6)