Children's Online Privacy Protection Rule Amendment--Comment, P994504

The Association of Educational Publishers appreciates the opportunity to provide these brief comments on the Federal Trade Commission's proposal to extend for two years -- to April 21, 2004 -- the period during which Web sites directed to children may use an e-mail message from the parent, combined with additional steps, to obtain consent for the collection of personal information from children.

Since April 2000, when the final rule implementing the Children's Online Privacy Protection Act went into effect, publishers have committed significant resources to meeting its existing requirements. And we believe the current "sliding scale" approach -- allowing Web operators who collect information for internal use only to pursue this less stringent form of consent -- has proved an effective way to balance parental involvement with children's freedom to pursue educational experiences online. Further mandates, therefore, would be an unnecessary burden. We support extending the sliding-scale provision indefinitely.

Members of AEP include the most respected names in software and supplemental publishing, school and teacher publications, and children's magazines; in educational foundations and associations; and in the education and trade press across all media, as well as schools and school districts. On behalf of our members and their various perspectives, AEP has long been involved in the issue of children's privacy online, first commenting to the FTC on the subject of COPPA in June of 1999.

We continue to advocate solutions that balance children's right to privacy with their freedom to access educational products and services. We believe the current system has achieved its objectives: It is workable for publishers, and has sufficiently protected children.

We therefore recommend that the Commission extend the provision indefinitely.