Children's data needs a published retention policy
The requirementstatement
The privacy policy must publish a written data-retention policy for children's data, with the purpose, the justification and the deletion timeframe.
- Severityseverity
- HighHIGHRejected by at least one carrier or provider, and a common cause of failure at the rest.
- When it bitesphase
- Gates approvalapprovalGet this wrong and the brand or campaign is refused at registration.
- What is checkedobject
- privacy policy body
- Where it liveslayer
- Policy pagesPOLICY_PAGE
- How Ekas settles itdetectability
- AI · formAI_FORM
- A semantic question about what you wrote: whether a description matches a use case, whether a name looks like a filed entity. Judged by a model against written criteria.
- What the fix involvesfailureClass
- Fix the policyTERMINAL_POLICY
- The fix lives in your privacy policy or SMS terms. Ekas can generate the missing clauses.
- Who requires itauthorities
- FTC
- When it appliesapplicabilityText
- Applies to every 10DLC registration.
Why this rule existsrationale
The 2025 COPPA amendments require the retention policy to be published rather than merely held, which is a change most businesses have not noticed. The substance matters as much as the publication: a retention rule with no deletion timeframe is a commitment to keep a child's data indefinitely, stated in public.
How to fix itremediation
Add the retention rule to the children's section: what is kept, why, and for how long. Done when the section states a period rather than a condition.
A compliant exampleexample
Where we learn that a subscriber is under 13 we delete the number and its consent record within 30 days, keeping only the fact of the deletion.
Notesnotes
Conditional on children's data being in scope, which no applicability dimension expresses; the criteria pass immediately where it is not.
Rules you will hit next
6 other rules read privacy policy body. Fixing one field to satisfy a single rule is how a resubmission trades one rejection for another, so read these before you change anything.
POL-050Privacy policy must state mobile opt-in data is not shared or soldBlockingBLOCKINGPOL-063A policy that says mobile opt-in data is shared is refused outrightBlockingBLOCKINGPOL-078A political brand is held to the same data-sharing banBlockingBLOCKINGPOL-079A charity policy must bar anyone but the charity from using subscriber dataBlockingBLOCKINGPOL-109A cart-reminder programme must say how abandonment is detectedBlockingBLOCKINGPOL-053The clause must say NOT SHARED, not merely "not sold"HighHIGH
POL-115 is one of 157 policy pages rules in the 915-rule 10DLC registry. Free to cite under CC BY 4.0.