Submission Number: 00048
Received: 12/14/2011 10:46:42 AM
Commenter: Stacey Pusey
Organization: Association of Educational Publishers
Agency: Federal Trade Commission
Initiative: 16 CFR Part 312; Children’s Online Privacy Protection Rule Review; Project No. P104503
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COPPA Rule Review, 16 CFR Part 312, Project No. P-104503
On behalf of the Association of Educational Publishers (AEP), its Board of Directors, and our membership of more than 300 organizations, I am submitting comments on the Federal Trade Commission's proposed amendments to the Children's Online Privacy Protection Rule. We appreciate the opportunity to provide feedback.
In 2001 AEP advocated to keep the email-plus method for obtaining parental consent when information is used for internal purposes only. We recommend that the Commission continue to maintain this provision. AEP supports the need to protect children online, but we believe that the current proposal to eliminate email-plus as a parental consent mechanism will actually create barriers for children, parents, and publishers.
Our full comments and recommendations are attached. Thank you for the opportunity to submit our comments.
The Association of Educational Publishers