What if your company had a buffer between it and the Federal Trade Commission, just as it's enacted tough new rules in the Children's Online Privacy Protection Act (COPPA) — someone who could pick up the phone and ask agency staff a question on your behalf, or provide you with warnings on noncompliance before a government investigator knocked on your door?

As sweeping, amended privacy regulations took effect on July 1, companies have long been taking advantage of such a shield: the FTC-approved safe-harbor programs, a kind of shelter built into COPPA.

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