16 CFR Part 312; Children’s Online Privacy Protection Rule Review; Project No. P104503 #00048 

Submission Number:
00048 
Commenter:
Stacey Pusey
Organization:
Association of Educational Publishers
State:
Delaware
Initiative Name:
16 CFR Part 312; Children’s Online Privacy Protection Rule Review; Project No. P104503

COPPA Rule Review, 16 CFR Part 312, Project No. P-104503 Secretary, 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. Respectfully, Stacey Pusey Content Manager The Association of Educational Publishers