Submission Number: 547597-00035 

Received: 6/30/2010 7:22:32 PM
Commenter: Martine Niejadlik
Organization: BOKU, Inc.
State: California
Agency: Federal Trade Commission
Initiative: 2010 Children's Online Privacy Protection Act Rule Review
Attachments: No Attachments
Submission Text
- Verification Methods - We feel it is important for the Comission to continue to outline acceptable methods of verification and the associated privileges that come with each form, as well as to continue to keep the law open to new, equivalent methods that take advantage of advances in technology and household utilization. To that end, we propose specifically including Mobile SMS (short message service) parental authorization with privileges similar to credit card when a charge/transaction occurs along with the verification and similar to email plus privileges when there is no charge. We feel this a much stronger verification method than email plus since, in general, people do not have access to more than one or two phones and/or the ability to open many accounts, parents are typically issuing phones to children, most parents have phones themselves and children should know their parents number (in all likelihood, probably better than the parents email). - Definition of Personal Information – we strongly encourage the Commission that if a decision is made to include IP Address, device data or any other data automatically captured during interaction with a user and a web site into the definition of personal information that this is regulated by USE of the data and not by the data capture itself or the storage of such data. When considering the protection of children, one must also consider that one way to protect children is to keep bad people away from them. Such “machine” data is critical information in the detection and prevention of fraud and other bad activities. - We recommend keeping the law written to capture Actual Knowledge, as suspected/constructive knowledge would be too difficult to comply with.