COPPA just covers information collected online from young ones. It will not protect information gathered from grownups that could pertain to young ones. Therefore, COPPA is certainly not set off by a grown-up uploading photos of kiddies on an audience that is general or perhaps in the non-child directed percentage of a mixed-audience site.
Nonetheless, operators of sites or online solutions which are mainly directed to kids (as defined by the Rule) must assume that anyone uploading an image is a kid in addition they must design their systems either to: (1) give notice and obtain previous consent that is parental (2) eliminate any youngster images and metadata just before publishing, or (3) produce an unique area for publishing by grownups, if that may be the intention.