Amazon's Echo Dot Kids, a smart speaker designed for children, fails to adequately protect children's privacy by illegally keeping data on children even after their parents try to delete it, according to a new complaint from consumer advocacy groups.
The complaint, filed by a coalition of 19 consumer and public health advocates led by the Campaign for a Commercial-Free Childhood (CCFC) and the Center for Digital Democracy (CDD), asks the Federal Trade Commission to investigate Amazon and the $35 device.
Amazon markets the device as "a kid-friendly study buddy, DJ, comedian, storyteller, and more," and promises "peace of mind" for parents who want to screen explicit music and other potentially harmful content from their kids. But the complaint alleges that parents may be risking their children's privacy, alleging the kids' version of Amazon's Alexa won't forget what children tell it, even after parents try to delete the conversations.
"These are children talking in their own homes about anything and everything," said Josh Golin, who directs the Campaign for a Commercial Free Childhood. "Why is Amazon keeping these voice recordings?"
In a statement, Golin added, "The real purpose is to amass a treasure trove of sensitive data that it refuses to relinquish even when directed to by parents."
A coalition of groups led by Golin's organization and Georgetown University's Institute for Public Representation is filing a formal complaint with the FTC alleging that Amazon is violating the federal Children's Online Privacy Protection Act, known as COPPA, by holding onto a child's personal information longer than is reasonably necessary.
Amazon said in a statement that its Echo Dot Kids Edition is compliant with COPPA.
Amazon Echo Dot: Privacy
In one example the advocates captured on video, a child asks the device to remember some personal information, including her walnut allergy.
An adult later tries to delete all that information, which includes the voice recordings and written transcripts associated with them. But then, when the child asks what Alexa remembers, it still recalls that she's allergic to walnuts.
"This suggests that Amazon has designed the Echo Dot Kids Edition so that it can never forget what the child has said to it," the complaint says.
Alexa "skills" created by outside developers
The complaint also says that about 85% of the more than 2,000 games, quizzes and other Alexa "skills" aimed at kids did not have privacy policies posted. Such skills are generally produced by independent software developers or other third parties, not Amazon.
It's unclear whether the FTC will take up the complaint, since its investigations are rarely public. But the agency has been enforcing children's privacy rules more seriously in the past year, said Allison Fitzpatrick, a lawyer who helps companies comply with COPPA requirements and was not involved in the complaint.
That was the case earlier this week, when the agency issued a warning to a Ukrainian firm that its three dating apps appeared to violate COPPA because they were accessible to children, which led Google and Apple to pull them from their app stores. Earlier this year, the FTC imposed a $5.7 million fine on popular video-sharing app TikTok, the largest COPPA-related penalty since the law was enacted two decades ago.
For the FTC to take notice, however, Fitzpatrick said there usually needs to be evidence of "real, actual harm," not just the theoretical harm she said advocacy groups often outline.
But Fitzpatrick said that, on their face, the new allegations against Amazon appear troubling. She said the FTC provides an exemption that enables a business to collect a child's voice recording without parental consent, but that's only for a temporary and specific purpose — such as to perform an online search or fulfill a verbal command.