16 CFR Part 312; Children’s Online Privacy Protection Rule Review; Project No. P104503 #00203 

Submission Number:
00203 
Commenter:
Kristin Eno
Organization:
Little Creatures Films
State:
New York
Initiative Name:
16 CFR Part 312; Children’s Online Privacy Protection Rule Review; Project No. P104503

I am a mother, early childhood educator and filmmaker. I make films with and for children and as a result, maintain a healthy fear of media's effects on children's lives. I am writing to express my concern about that fact that the COPPA Rule has not been updated in over ten years. There are loopholes in the current version of the COPPA Rule that make it easier for advertisers to do one-to-one marketing strategies on children without parental consent. I encourage the FTC to take into account that parents are often not educated enough in logistics and often do not read/understand the fine print enough to understand privacy and advertising policy notices. Allowing the COPPA Rule to remain in effect as it was written in 2000 is essentially not fair to parents, who are dealing with a very different internet landscape 11 years later. Not changing COPPA to reflect these differences indicates irresponsibility on the part of the FTC. The COPPA Rule should be updated to clarify that operators must ask parents’ permission before they collect: * Children’s IP addresses * Children’s geolocation information * Children’s screen and user names * Photographs and videos of children Please update the COPPA Rule. We parents, educators and makers of media need the FTC to ensure that COPPA does the best job it can do at protecting children and assisting parents. Thanks for your time and best wishes, Kristin B. Eno Director, Little Creatures Films Brooklyn NY