Submission Number: 00351
Received: 12/23/2011 2:49:34 PM
Commenter: Larry Magid
Agency: Federal Trade Commission
Initiative: 16 CFR Part 312; Children’s Online Privacy Protection Rule Review; Project No. P104503
00351-82377.pdf Size = 196 KB
00351-82378.pdf Size = 1333 KB
Download Adobe Reader
I am writing to suggest that the COPPA rules be amended so as not to prevent children under 13 from participating in social media or to maintain barriers that make it prohibitively expensive and burdensome for social media companies to welcome children under 13.
While I understand the original intentions of COPPA, it was clearly written before the advent of social media.
Study after study has shown that children are not at an increased risk as a result of their participation in social media. And, although it's a correlation with only an inferential basis for causation, a recent study by the Crimes against Children Research Center found that both unwanted sexual solicitation and unwanted exposure to pornography have declined since 2000 and the advent of social media (see attachment).
I am also concerned about the fact that millions of children (and their parents) are lying to get their kids on Facebook. Based on the data, it is clear that many parents have made an informed decision to allow their under 13-year-old children on Facebook yet they must lie to make this happen. That is not good role modeling or is it good federal policy to inadvertently encourage parents to help their children lie.
Also, as a safety advisor to Facebook, Google and other social networking companies, it strikes me that COPPA actually discourages these companies from providing safety and privacy resources for children under 13, because, in theory, these children are not allowed on the services. It is my belief that children would be safer if they were legally able to participate in social networking sites and given age-appropriate educational resources, parental controls and restrictions which is only possible if we remove the incentive for children to lie about their age.
I have attached other articles that I've written on the subject of social media and youth risk as well as a PDF of a slide show on the risk of fear and exaggeration when it comes to youth online risk.
Founder & Editor, SafeKids.com