AI & Data Companies

AI and data companies face risks that standard control sets often miss: prompt injection, sensitive information disclosure, model and data poisoning, supply-chain vulnerabilities, and excessive agent autonomy.

Our approach: Standard COPPA readiness first. AI and data-specific hardening second. The advisory modules below are optional enhancements on top of mandatory controls.

Standard Controls vs. AI/Data Enhancements

Standard COPPA Readiness

Mandatory controls required for compliance:

  • Logical access and privileged access
  • Change management
  • Incident response
  • Risk management
  • Vendor management
  • Backup and availability
  • Logging and monitoring
  • Confidentiality and privacy (where applicable)

View all control domains →

AI/Data Advisory Enhancements

Optional modules justified by AI-risk frameworks:

  • Data lineage and training data governance
  • Prompt/response telemetry
  • RAG and retrieval governance
  • Model/provider vendor review
  • Agent approval gates
  • AI-assisted SDLC controls
  • Warehouse and analytics governance

Advisory Modules

Each module adds specific controls and documentation practices to address risks unique to AI and data-intensive products.

AI-Assisted SDLC Controls

AI-generated features on child-directed platforms must be reviewed for COPPA compliance before deployment — automated code and content generation can inadvertently introduce PI collection points or age-inappropriate interactions.

What This Module Adds

  • COPPA compliance review gates for AI-generated features targeting child audiences
  • Child-safety testing for AI-generated outputs before deployment to child-directed services
  • Age-appropriate content filtering validation for AI-assisted content generation
  • PI collection impact assessment for AI features embedded in child-directed applications

Human Review & Agent Gates

Automated interactions with children require heightened human oversight to prevent inappropriate content exposure or unauthorized PI collection through conversational AI agents.

What This Module Adds

  • Human review of AI-generated responses before delivery to child users
  • Content safety gates that filter AI outputs for age-appropriateness and PI solicitation
  • Escalation procedures for AI interactions that detect or inadvertently collect children's PI
  • Audit trails for all AI agent interactions with child-identified users

Model Provider & Vendor Risk

AI model providers processing children's PI are subject to COPPA operator liability under § 312.8 — the operator cannot outsource compliance by outsourcing the processing.

What This Module Adds

  • Children's PI handling restrictions in all AI model provider contracts
  • Training data exclusion verification ensuring children's PI is not used to train third-party models
  • Age-appropriate output requirements for model providers serving child-directed applications
  • Right-to-delete cascade requirements for children's PI processed by model providers

Prompt & Response Logging

Logging AI interactions with children may constitute PI collection requiring parental consent — persistent logs of children's prompts and system responses can contain identifiable information subject to COPPA.

What This Module Adds

  • Minimal logging policies for children's AI interaction sessions
  • Parental consent requirements for any persistent logging of children's AI interactions
  • Automatic deletion schedules for children's session logs aligned with COPPA retention limits
  • PI detection and redaction in children's prompt and response logs

RAG & Vector Store Controls

Vector stores must not embed children's PI without consent, and the right to delete must be technically feasible for embedded data — standard vector deletion is non-trivial and requires purpose-built processes.

What This Module Adds

  • Children's PI exclusion from vector store embeddings and retrieval corpora
  • Parental deletion cascade to vector stores containing children's embedded data
  • Age-tagged data isolation preventing children's data from entering general-purpose RAG pipelines
  • Periodic audits of vector store contents for unauthorized children's PI

Training & Inference Data Governance

Using children's behavioral data for model training violates COPPA's purpose limitation without specific parental consent — the FTC has signaled that repurposing children's data for AI training is an enforcement priority.

What This Module Adds

  • Prohibition on using children's data for model training unless covered by specific parental consent
  • Data provenance verification ensuring training datasets do not contain children's PI
  • Age filtering in training data pipelines to exclude child-originated content
  • Inference-time controls preventing children's PI from being cached or retained by model infrastructure

Warehouse & Analytics Governance

Analytics on children's behavior must comply with COPPA data collection limitations and cannot support behavioral advertising — data warehouse practices that are routine for adult users may violate COPPA when applied to children.

What This Module Adds

  • Prohibition on behavioral profiling of children in analytics warehouses
  • Aggregation-only analytics for children's usage data to prevent individual-level tracking
  • Advertising restriction enforcement preventing children's data from flowing to ad-tech pipelines
  • Separate data governance policies for children's data within shared warehouse infrastructure

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