Submission Number: 547597-00056
Received: 7/7/2010 2:41:14 PM
Commenter: Mary Kay Hoal
Agency: Federal Trade Commission
Initiative: 2010 Children's Online Privacy Protection Act Rule Review
Attachments: No Attachments
1. Identity verification is absolutely do-able. Parents of Yoursphere.com(http://yoursphere.com/) members have shown that they are willing to have their identities verified (http://yoursphere.com/safety-first) for the sake of their children. While the Yoursphere ".com" site is just for kids in the United States due to the highest safety standards, we are expanding under different URLs to other countries, i.e. Yoursphere.co.uk, because people from all over the world have tried to have their identity verified by Yoursphere.com on behalf of their children. An added benefit to identity verification for children is that no one is anonymous on our site. It helps to decrease behavior afforded by anonymity and allows kids to freely be themselves while providing parents with some peace of mind. 2. My experience over the last three years is that 99.99% of the parents I talk to through my work, or the media professionals I've been interviewed by, typically have no idea what COPPA is. (What is COPPA (http://bit.ly/czOvQ5); What to say to your underage child re. COPPA (http://bit.ly/9eg2y6)). I try to use every opportunity I have through the media to educate parents about COPPA. (http://yoursphere.com/press)(http://bit.ly/biF2tV) 3. Parents every day provide an ample amount of personal information in order to get their child a cell phone (name, address, dob, full social security, credit card number). Identity verification at Yoursphere asks parents for less information then what it takes to get a cell phone phone (name, address, dob, and last 4 of social to verify) and parents will supply the data. An important distinction from other methods promoted by the FTC is that most adults do not carry in their wallet or keep around the house in generally available ways their social security number. Accordingly, we believe this is a unique identifier that the average child would not have access to. Because the partial SSN is something that parents are accustomed to using to authenticate themselves to their financial and credit services and the fact that they don’t have to leave their chair to provide the information makes it an easy and low friction choice for parents to use. This method provides a cost effective, immediate and scalable online response for Yoursphere to validate identities. Yoursphere does not retain the SSN4 information. 4. While the FTC and COPPA does not extend to identity verification on the Sex Offender Registry, it's easy to do. Yoursphere does it, but the cost needs to be lowered so all sites geared towards children can afford it. (Registered sex offenders are not allowed by law to be within a specified number of feet of a school, or to work with children, yet no barriers exist online. That simply is wrong irregardless of the statistics that say only a small percent of children will be preyed upon.) 5. The cost for identity verification can be done for the same price as a credit card transaction fee. It is affordable. Yoursphere has used two different identity verification providers so we are very familiar with the cost structure. Over the last 3 years, the pricing has become more affordable. 6. Sites that market themselves for adults in my opinion shouldn't have to verify identities, yet they should use reasonable technology methods to keep COPPA protected kids off their site. It's easy to do. It's a sad fact that according to a MacAfee research study (http://bit.ly/aJuSlQ), that 37% of 10-12 year olds are on the world's largest social networking site yet those accounts aren't deleted. My nine year old son has told me a number of times about the 1st graders at his school on this network. Additionally, teens 13 - 17 should have added privacy and content protection, and should not be asked for personally identifiable information (phone number, email, IM address, school, address) in order to set up an account. We don't ask phone number, address, school, email address, IM, etc. for any Yoursphere youth member.