Response to the Federal Trade Commission Workshops on the
Children’s Online Privacy Protection Rule
KEEPING PARENTS IN THE LOOP ON A KID-CENTERED SITE
Submitted by: The FreeZone Network
August 6, 1999
The FreeZone Network is positioned to be the global leader in online youth communities, by connecting millions of kids through local and global communities of interest in print, online and other media. The Network is best known for FreeZone.com (http://freezone.com), the only kids Web site that is 100 percent monitored and screened by trained, adult employees.
The goal of The FreeZone Network is to create a generation of youth empowered with the communication, technical and emotional skills necessary to succeed in all aspects of their lives ... and let them have a lot of fun in the process! Today, with more than 380,000 registered users, FreeZone is still the only fully monitored site on the Web for kids. Nearly 90 percent of the content on FreeZone is written and created by kids ages 8 to 14.
FreeZone works closely with the Children’s Advertising Review Unit (CARU) and the FTC to ensure we continue to meet -- indeed, exceed -- safety and privacy standards. Our purpose in submitting this statement is to inject the case for self-driven privacy practices into the COPPA discussion among the FTC, Web sites and industry watchers.
Online Children’s Communities and COPPA
The FreeZone Network endorses and practices verifiable parental notification/consent in the most stringent manner possible. In fact, we continually strive to do more. Our business is based on the highest possible safety and privacy standards that have become our competitive advantage in drawing kids into the FreeZone community. We are eager for technology to catch up to our standards, so we can implement more convenient and cost-effective ways to gain parental consent.
Currently we collect parental consent via postal mail or fax copies of registration forms for children 12 and under. This process is outlined below. We are exploring the use of a 1-800 number for parental consent. While credit card numbers are verifiable, to date we have not asked for them because we are not a subscription service. We are exploring future technologies and systems to meet our needs and want to make the process quick and seamless for users and as easy for parents and guardians as possible while not compromising our standards.
Our message to the FTC is this: the industry is still learning how to perfect parental notification/consent. We need the freedom to continue to learn what will be effective for the industry as a whole. There is not yet a singular, smart method of verifiable parental consent that can serve the myriad interests still carving niches into the kids online world. Companies interested in communicating with children online need to rise to the responsibility and realize there is a high level of accountability required online as the world become more comfortable with this new exciting medium.
FreeZone will continue to serve as a leader in privacy and safety among peer Web sites, regardless of FTC decisions to formulate rules.
Parent Involvement in a Kid-Driven World
We communicate with parents and guardians in many ways to assure children’s privacy.
The Registration Process. Our online membership sign-up page requests a date of birth. Online registration for kids 13 and older are immediately processed, and an automatic e-mail is sent to them and their parents informing them that their registration has been accepted. Parents have the right to unregister their kids.
Upon filling out the online membership page, kids who are 12 and under are immediately sent to a second page that is a print-out registration form (kids can not back up from this page to get back into the site). Kids can print and fill out this form, but their parents must sign the form and send it to FreeZone by fax or U.S. mail. Once we receive completed, signed print-out registration forms, they are processed within 24 hours and automated e-mails are sent to the child and their parents notifying them of their completed registration. For those kids who do not have printers, FreeZone will mail or fax registration forms to their homes upon request.
Additional Notifications. When kids contribute to the site, such as by submitting articles, we contact parents again for permission. Parents may decline our use of their kids’ contributions. Parents also must be notified when a child wins a contest.
FreeZone appreciates this opportunity for the industry to exchange information and thanks the FTC for its efforts to protect children and open the dialogue.
FreeZone’s privacy statement can be viewed at http://freezone.com/safety/privacy.html. This area is accessible from any page on FreeZone. For more information, please contact Justin Osmer, Marketing Manager at: 312-705-3835 or email@example.com.
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