Submission Number: 00036
Received: 11/16/2011 12:51:32 PM
Commenter: Renee Ramig
Organization: Seven Hills School
Agency: Federal Trade Commission
Initiative: 16 CFR Part 312; Children’s Online Privacy Protection Rule Review; Project No. P104503
Attachments: No Attachments
The COOPA rule as written keeps usable online tools out of the hands of students. Most websites, even those whose tools are completely appropriate for students under 13, will create rules of 13 or older because of their fear of being sued because of COOPA.
Many kids under 13 now have email accounts as well as use social networking sites for school and for personal use. There is no longer the need to have the under 13 rule for personal information for all websites.
I believe the rule should be changed to focus on sites that are for adults 18 and older. Sites appropriate to those under 18, should not have a 13 year old cut off. It keeps great tools out of the hands of middle school students. Students will be using social networking tools for the rest of their life. One of the things schools need to be teaching is how to use them appropriately. We need to be teaching kids how to create a positive digital footprint. This is being hindered by COOPA. Please change it.