Submission Number: 00006
Received: 9/16/2011 1:02:29 PM
Commenter: Mark Williams
State: Outside the United States
Agency: Federal Trade Commission
Initiative: 16 CFR Part 312; Children’s Online Privacy Protection Rule Review; Project No. P104503
Attachments: No Attachments
I agree wholeheartedly with the principle of this move but I must strongly object to the open-ended nature of the wording and by extension, the efficacy of this strategy as a whole. In terms of a 'measure' or 'procedure'; I'd like to know:
1. what is 'reasonable' and
2. by whom is it to be defined?
4 examples from paragraphs 4 & 6 of the original article:
1. take reasonable measures
2. reasonable procedures to protect
3. as is reasonably necessary
4. taking reasonable measures
Whom does this protect? it looks, to me, very much like a legal argument which will be paid for by the hour, after the fact.
Why can everybody not be reading from the same page? Surely a clear distinction between what is legal and what is not is a necessity here?