Submission Number: 561789-00023
Received: 9/20/2012 1:17:22 PM
Commenter: Chris Drzewiecki
Agency: Federal Trade Commission
Initiative: 16 CFR Part 312; Children’s Online Privacy Protection Rule; Supplemental Notice of Proposed Rulemaking; Project No. P104503
Attachments: No Attachments
As a developer, I am deeply concerned over the requirement that developers of plugins must be subject to the same COPPA requirements, even though it is not them but their client (the web site accessible to children) which is collecting the data. It is not a reasonable burden to put on such developers to investigate what each and every client or user is doing with their software - particularly as the number of users might be so large as to be impossible to keep track of.
As it is not the developer of the plugin themselves, but the web site using the plugin, which is collecting any data, the burden should not fall on the developers on this matter. I urge you to reconsider this.