16 C.F.R. Part 312; Children's Online Privacy Protection Rule Safe Harbor Proposed Self Regulatory Guidelines; kidSAFE Seal Program Application for Safe Harbor; Project No. P 135418 #00004

Submission Number:
00004
Commenter:
Teresa Tersol-Wiseman
Organization:
Knowledge Adventure, Inc./JumpStart
State:
California
Initiative Name:
16 C.F.R. Part 312; Children's Online Privacy Protection Rule Safe Harbor Proposed Self Regulatory Guidelines; kidSAFE Seal Program Application for Safe Harbor; Project No. P 135418

Knowledge Adventure, Inc., doing business as JumpStart, operates a series of educational children’s websites and are deeply committed to ensuring the highest level of online privacy for our users. We have been in discussions with Mr. Samet and the kidSAFE organization since the organization’s beginning days and are proud to display the kidSAFE seal on our primary sites. We have continually been impressed with Mr. Samet and his organization’s dedication to educating website owners to the Children’s Online Privacy Protection Act (“COPPA”). We have attended a number of online webinairs conducted by kidSAFE and have found them highly informative and demonstrative of a clear understanding of both the regulatory as well as operational and ethical aspect of online safety – particularly as it impacts children. We have reviewed the kidSAFE application and proposal for a COPPA Safe Harbor Program under COPPA and find it a comprehensive proposal to provide a Safe Harbor program that not only meets COPPA’s regulations but exceeds it in certain areas to the benefit of the child’s privacy. In addition the proposed program provides an excellent framework for site operators seeking to ensure that their sites not only comply with COPPA but with the overall intent of protecting children’s online safety and privacy. The proposed kidSAFE Seal Program provides a mechanism for operators to not only ensure annual compliance with COPPA but also internal assessments and ongoing compliance support which is critical to any website that has ongoing improvements, modifications and content. In addition the kidSAFE Seal Program online complaint mechanism will be useful in allowing site operator’s feedback and overseeing of its web operations. Such online complaint mechanisms are valuable in the sense that complaints are immediately forwarded allowing for prompt investigation and correction as needed. We believe that the addition of the kidSAFE Seal Program to the FTC’s COPPA Safe Harbor programs would be beneficial to the consumer – both parent and child as well as to those site operators who understand and appreciate the complexities of COPPA compliance.