Evaluating the Contextual Integrity of Privacy Regulation: Parents' IoT Toy Privacy Norms Versus COPPA

Abstract: Increased concern about data privacy has prompted new and updated data protection regulations worldwide. However, there has been no rigorous way to test whether the practices mandated by these regulations actually align with the privacy norms of affected populations. Here, we demonstrate that surveys based on the theory of contextual integrity provide a quantifiable and scalable method for measuring the conformity of specific regulatory provisions to privacy norms. We apply this method to the U.S. Children's Online Privacy Protection Act (COPPA), surveying 195 parents and providing the first data that COPPA's mandates generally align with parents' privacy expectations for Internet-connected "smart" children's toys. Nevertheless, variations in the acceptability of data collection across specific smart toys, information types, parent ages, and other conditions emphasize the importance of detailed contextual factors to privacy norms, which may not be adequately captured by COPPA.