Submission Number: 00045
Commenter: Jun Song
Agency: Federal Trade Commission
Initiative: 16 CFR Part 312; Children’s Online Privacy Protection Rule Review; Project No. P104503
Attachments: No Attachments
The Commission’s proposal to amend the Children’s Online Privacy Protection Rule, COPPA Rule, seems to contain more restrictions and guide to the websites, parents and also Children. Trying to change rule made in April 2000 seems to be an appropriate change for children in these days.
However, there are a few things I would like to propose regarding what is the best for the children. Iphones came out 2007, and it is not easy to find a cell phone, which is not smart-phone. Androids, Iphones, Google Phone; there is even a phone company sells pre-paid plans with smart phones. They are not hard to have any more. Finding a usual cell phone would be more difficult.
How about internet? Google is just getting better; finds whatever I type in, Youtube shows any video clips which posted by people, even espn gives news from MMAs as UFC and so on. It is not only news, articles or comments. There are actual photos and videos of violent scenes on internet. It is just everywhere.
What I am trying to say is your propose to strength the protection of information of children through parents’ consent and make the security better is good; but not good enough. According to your proposal, you recommend the operators to provide notice to parents and obtain verifiable parental consent prior to collecting, using, or disclosing personal information from children under 13 years of age, and I think it is not enough.
The rule you have proposed might be able to alert parents and children, may be have them think about the importance of personal information, but that may allow children to think that that is the ‘only’ thing they have to care for. Once be sure about their information security, they may say, ‘oh I have passed the security issue, there’s nothing I cannot do with it.’ That can be a problem.
To mention an exaggerated example, if I try to find out sex or murder on internet, there would be tens of thousands of photos and information, which will be t