|Received:||2/9/2005 2:23:30 PM|
|Agency:||Federal Trade Commission|
|Rule:||Notice of Proposed Rulemaking, Request for Comment|
Comments:Dear Secretary Clark: I am writing to express my opposition to the proposed rule change regarding Email Plus. I have been actively involved in Internet Marketing for the past 7 years. As both a parent and industry professional, I am would be extremely concerned and disappointed if Email Plus is extended or made permanent. I am confident that it is too easy of a task for children to circumvent their parent from the notification process with the Email Plus process. It is clear that Generation Y is extremely knowledgeable and savvy about using the Internet. They are comfortable with the medium and know how to navigate easily from site to site. They actively engage in multitudes of activities and want to be as involved in sites as possible. However, children are extremely vulnerable and can be naïve about giving out their personal information without understanding the ramifications. It was my understanding that the original purpose of COPPA was to set distinct guidelines that would involve the parent’s in this process, so that they could be made aware and empowered to authorize where and when their children are disseminating personal information. The amended rule seemed necessary at the onset of the legislation, as I understood that the technology was not yet available. I have seen some sites that have set into motion a verification procedure that ensures that a parent is involved in the process. As the industry continues to grow, it would seem logical that more opportunities will become available. I hope that the FTC will not settle at this point and make a rule part of law that in fact weakens the law. Our children and their personal information is at stake here, and every effort should be made to seek the highest standards in this regard. Also, I think it is vital for children to learn that involving a parent is for their own safety and is a necessary part of the process. Giving parent’s more power is a good thing!