Handling minors’ data has become more complex as enforcement attention increases. That pressure grew last week when an FTC commissioner warned the agency is preparing to act against the “mass monetization” and profiling of children. Further underscoring these concerns, newly released research shows that children’s personal data is commonly shared without consent, while recent FTC and California enforcement actions reveal deep probes into companies’ controls around such sharing, including oversight of third-party software development kits. This article examines recent regulatory focus on the sharing of minors’ data, distills research findings and offers practical data management steps, including guidance on data-flow inventories and key contracting terms, with input from practitioners at Foley Hoag, Hunton and Pixalate. See “Enforcement Lessons From Disney and Four Other FTC Children’s Privacy Actions” (Jan. 28, 2026).
