From: JohnSKirk@aol.com
To: HQ.DCMAIL4(KIDSRULE)
Date: Fri, Jun 11, 1999 5:34 PM
Subject: Comment on Children's Online Privacy

Why are you interfering with the ordinary course of e-commerce? It is great to protect children, but most businesses do not target children under 13 because they don't usually have credit cards or checkbooks. Our business sells computer software of the type normally purchased by adults or other businesses, address book and calendaring software. Why should we have to worry about breaking a privacy law if a 12 year old purchases our software.

We maintain information on name, address, e-mail address, and what was purchased. Why should we have to give up valuable space on our Web pages to this proposed regulation?

If an 8-year old visits the corner drug store every Saturday with his $1.00 allowance to buy a weekly candy bar. Should the drug store be prohibited from remembering that the child's name is Johnny? Should they be fined because they welcome the child with, "Hello there Johnny. Will it be a Mars bar again this week?" The drug store is keeping a mental database of information on a regular customer.

If all we need to do is what Proctor and Gamble has done, which is to include the following statement in with a general privacy statement, it is not too onerous. But it appears that you are needlessly imposing regulations on all businesses, where no regulation is needed. P&G has the following:

Children

Procter & Gamble has no intention of collecting any personally-identifiable information (that is, name, address, telephone number, or email address) from individuals under thirteen years of age. Where appropriate, Procter & Gamble will specifically instruct children not to submit such information on our websites or advertisements. If a child has provided us with personally-identifiable information, a parent or guardian of that child should contact us at the email address or phone number listed at the bottom of this Statement if they would like this information deleted from our records. We will use reasonable efforts to delete the child's information from our existing files.