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 #00012

Submission Number:
00012
Commenter:
Harry Valetk
State:
New York
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

I submit comments on three key concerns with this kidSAFE Seal Program. I submit these comments in my own capacity as a data protection attorney with over 15 years experience devoted to information security, technology, and online child safety. For the reasons I more fully explain in my attached comments, I recommend that the Federal Trade Commission reject this application for COPPA Safe Harbor. Thank you for the opportunity to participate in this public comment process.