i-SAFE, Inc. Application for Safe Harbor #546345-00008

Submission Number:
546345-00008
Commenter:
Jodell Seagrave
Organization:
Rocket21 Enterprises
State:
CA
Initiative Name:
i-SAFE, Inc. Application for Safe Harbor

To whom it may concern: Over the last decade, I have held several executive-level positions for organizations providing Internet content and services for children under thirteen. In those roles, I have necessarily become a student of COPPA, an ongoing professional effort to be certain that each of those services has been compliant. Now, as a partner in a new venture, I have evaluated the firms participating in the FTC safe harbor program, in order to select a program that could ensure our latest offerings will be compliant as well. I included i-SAFE in our evaluation as I understand that i-SAFE is being considered as a safe harbor provider. When I visited their site I was surprised to see that they have a location which appears to invite children to provide PII. Based on my interpretation of COPPA, the i-SAFE site does not seem to be compliant. Given my understanding that the safe harbor requirements are both specific and rigorous, it is difficult to reconcile how a firm could be under consideration for this designation if the provider offers services that themselves are not compliant. How can the FTC seriously consider i-SAFE when they do not meet COPPA standards in their own offerings? Given what I have seen there to date, I would be uncomfortable purchasing i-SAFE safe harbor services if they were designated an FTC approved provider. Further, if the standards are not applied consistently among approved safe harbor providers, the resulting marketplace confusion will likely deter other web operators who are similarly interested in meeting and exceeding the FTC standards. Respectfully submitted, Jodell Seagrave President & COO Rocket21