2010 Children's Online Privacy Protection Act Rule Review #547597-00001 

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2010 Children's Online Privacy Protection Act Rule Review

With regard to the FTC's query: "Whether parents are exercising their right under the Rule to review or delete personal information collected from their children, and what challenges operators face in authenticating parents" I've been in the computer business for over 26 years and worn many hats. The single biggest barrier to working effectively with computers, for anyone, is knowledge and training. As to kids, the responsibility for that *must* lie with parents/guardians. The FTC needs to promote parental computer literacy in a national campaign, and it needs to involve the software and hardware makers. Computers are like cars in that if you don't know what you're doing, it can cost you your life, your freedom, your identity, or bankrupt you, or all of the above. To expand on the car analogy: if it is left up to educators in the public schools to teach children how to be safe online (mostly, an illusion), and parents are not engaged in a meaningful way, then it is the schools who give our kids the keys to the "car" and the schools who turn them loose on the world without a "license to drive" (that should always come from the parents/guardians efforts) or any further supervision. It is not enough, and schools haven't the mandate for it either. (I'm not a school employee, just a parent.) We teach our children to drive by showing them what to do, and/or send them to a driving school. Then they get tested for licensure and we supervise their driving before they get any permanent license. In short, as parents we are involved in the process. We don't expect the highway patrol or other vehicle-related entities to shoulder the primary burden to teach our children how to be safe, and it is not reasonable to put the entire onus on schools and website owners (I'm not one of those either) to try to keep kids safe online. Parents must be educated and informed about computers, the internet, and tangential subjects before kids will have any safety leverage online, period. While there are many lazy parents who'd say "Yeah, yeah", and let their kids loose in a car or on a computer without proper training, we only get their attention when their kids get in trouble. At that point we apply the "ignorance is no excuse rule" -- but -- we neglected to remind them at the outset of their kids' online life that they themselves would be liable for the damage done by their offspring, and that there are few and toothless remedies when their kids are victimized in turn. So to recap, the FTC must not only engage parents, but must figure out a way to do so -- one possibility is to engage the biggest industry players by creating training hurdles in order for their software licenses to function, another is by non-electronic means, written permission letters even. In that spirit the FTC should work with Microsoft, HP, and other industry giants (no, I don't work for them either) to give clueless parents a leg up by having industry players make websites specifically for parents whose kids just received a computer. And PCs that won't connect to the internet without anti-virus and firewalls in functioning order. Some companies already do this (have parent websites) but unfortunately don't require any parental training before validating software licenses, when that simple step might help millions of parents. Most kids get education-level licensed software anyway because of the price differential. If every education-based software license had such a requirement, then many, many more parents would be a bit savvier and certainly more engaged, and kids would have one more layer of protection. Money to schools for parent training would help too. Data protection laws with some teeth would also go a long, long way toward protecting not only kids but everyone. It is not enough by any stretch to offer credit monitoring. And speaking of that, credit-reporting agencies need more scrutiny too, but that's another subject. A citizen.