YouTube channel owners: Is your content directed to children?

Share This Page

Under COPPA, how do I know if my channel is “directed to children”? Since the FTC and New York Attorney General announced their September 2019 settlement with YouTube for violations of the Children’s Online Privacy Protection Act Rule, we’ve heard that question from channel owners – sometimes called content creators. If you’re a channel owner who shares content on user-generated platforms like YouTube, read on for FTC staff guidance about the applicability of the COPPA Rule and how those covered by the Rule can comply with its requirements.

The FTC action against YouTube and Google

The lawsuit against YouTube and Google alleged that the companies illegally collected personal information from children, in violation of COPPA. According to the complaint, the companies collected that information from viewers of child-directed YouTube channels in the form of persistent identifiers that track users across the Internet, but didn’t notify parents and get their consent. To settle the case, YouTube and Google agreed to create a mechanism so that channel owners can designate when the videos they upload to YouTube are – to use the words of COPPA – “directed to children.” The purpose of this requirement is to make sure that both YouTube and channel owners are complying with the law.

A COPPA recap

That provision of the settlement has raised questions among content creators about how to determine if what they upload to YouTube or other platforms is “directed to children.” The answer requires a brief summary of some key COPPA provisions. Passed by Congress in 1998, the Children’s Online Privacy Protection Act is a federal law that protects the privacy of children under 13. COPPA’s foundational principle is one that most people can agree on: Parents – not kids, companies, platforms, or content creators – should be in control when it comes to information collected from children online.

The FTC enforces the law through the COPPA Rule. In general, COPPA requires operators of commercial websites and online services that are directed to children (more about that in a minute) to provide notice and obtain verifiable parental consent before they collect personal information from kids under 13.

The COPPA Rule defines “personal information” to include obvious things like a child’s first and last name or home address, but that’s not all. Under COPPA, personal information also covers what are called persistent identifiers – behind-the-scenes code that recognizes a user over time and across different sites or online services. That could be an IP address or a cookie when it’s used to serve targeted ads. Keep in mind that an operator also might be collecting personal information through an open comment field on its site or service that allows a user under 13 to make personal information publicly available. For example, think of a comment like this on a child-directed site: My name is Mary Jones from Springfield. I love this video!

How COPPA applies to channel owners

So how does COPPA apply to channel owners who upload their content to YouTube or another third-party platform? COPPA applies in the same way it would if the channel owner had its own website or app. If a channel owner uploads content to a platform like YouTube, the channel might meet the definition of a “website or online service” covered by COPPA, depending on the nature of the content and the information collected. If the content is directed to children and if the channel owner, or someone on its behalf (for example, an ad network), collects personal information from viewers of that content (for example, through a persistent identifier that tracks a user to serve interest-based ads), the channel is covered by COPPA. Once COPPA applies, the operator must provide notice, obtain verifiable parental consent, and meet COPPA’s other requirements. For information on how to comply with COPPA, please visit the FTC’s COPPA page for our Six-Step Compliance Plan for Your Business.

How channel owners can determine if their content is directed to children

Under COPPA, there is no one-size-fits-all answer about what makes a site directed to children, but we can offer some guidance. To be clear, your content isn’t considered “directed to children” just because some children may see it. However, if your intended audience is kids under 13, you’re covered by COPPA and have to honor the Rule’s requirements.

The Rule sets out additional factors the FTC will consider in determining whether your content is child-directed:

  • the subject matter,
  • visual content,
  • the use of animated characters or child-oriented activities and incentives,
  • the kind of music or other audio content,
  • the age of models,
  • the presence of child celebrities or celebrities who appeal to children,
  • language or other characteristics of the site,
  • whether advertising that promotes or appears on the site is directed to children, and
  • competent and reliable empirical evidence about the age of the audience.

The determination of whether content is child-directed will be clearer in some contexts than in others, but we can share some general rules of thumb. First, unless you’re affirmatively targeting kids, there are many subject matter categories where you don’t have to worry about COPPA. For example, if your videos are about traditionally adult activities like employment, finances, politics, home ownership, home improvement, or travel, you’re probably not covered unless your content is geared toward kids. The same would be true for videos aimed at high school or college students. On the other hand, if your content includes traditional children’s pastimes or activities, it may be child-directed. For example, the FTC recently determined that an online dress-up game was child-directed.

Second, just because your video has bright colors or animated characters doesn’t mean you’re automatically covered by COPPA. While many animated shows are directed to kids, the FTC recognizes there can be animated programming that appeals to everyone.

Third, the complaint in the YouTube case offers some examples of channels the FTC considered to be directed to children. For example, many content creators explicitly stated in the “About” section of their YouTube channel that their intended audience was children under 13. Other channels made similar statements in communications with YouTube. In addition, many of the channels featured popular animated children’s programs or showed kids playing with toys or participating in other child-oriented activities. Some of the channel owners also enabled settings that made their content appear when users searched for the names of popular toys or animated characters. Want to see the FTC’s analysis in context? Read pages 10-14 of the YouTube complaint.

Finally, if you’ve applied the factors listed in the COPPA Rule and still wonder if your content is “directed to children,” it might help to consider how others view your content and content similar to yours. Has your channel been reviewed on sites that evaluate content for kids? Is your channel – or channels like yours – mentioned in blogs for parents of young children or in media articles about child-directed content? Have you surveyed your users or is there other empirical evidence about the age of your audience?

What are the possible penalties for violating COPPA?

The Rule allows for civil penalties of up to $42,530 per violation, but the FTC considers a number of factors in determining the appropriate amount, including a company’s financial condition and the impact a penalty could have on its ability to stay in business. While Google and YouTube paid $170 million, in another COPPA case settled this year, the operator paid a total civil penalty of $35,000.

Isn’t the FTC taking another look at the COPPA Rule?

Yes, the FTC is currently evaluating the Rule in light of rapid changes in technology. If you would like to comment on the effectiveness of the COPPA Rule and whether changes are needed, the FTC has extended the comment deadline to December 9, 2019.

Where can channel owners go for more information?

A look at the factors in the COPPA Rule will help most channel owners determine if their content is directed to children. If you’re still unsure about how COPPA applies to you, consider contacting an attorney or consulting with one of the COPPA Safe Harbor programs – self-regulatory groups that offer guidance on how operators can comply with the law. Visit the FTC’s website for a list of currently approved Safe Harbor organizations. For more resources, visit the FTC’s Children’s Privacy page for our Six-Step Compliance Plan for Your Business.

 
 
 

Comments

What about anime? Anime is colorful and animated and some have bright music, but not all Anime is geared towards children. Like there's many animes out there that have blood, gore, adult language and partial nudity would those channels be taken off of YouTube or the people gonna be fined??

So wait?? YouTube is going to put 18+ ads before content if it's deemed not for children? If I want those kinds of ads, I know where to find them. As a viewer I have no desire to see them and kids are still going to watch YouTube regardless of whatever stupid restrictions you put in place. As a family friendly creator, I refuse to support YouTube and the FTC in censorship by telling me and my family what I can/can't watch and discrimination by rewarding content creators that are "edgy" with more ad revenue.

Youtube was already hard enough to upload onto, with demonetisation and all, but THIS??!! this is uncalled for
What about educational videos? They have animation and moving objects such as animation, and vibrant colours
You are not protecting the kids you are taking away all the things they come to YouTube for, you are removing people's jobs without them having any kind of say, and the fact that it's not their fault, that parents don't monitor their kids
I also do not understand how a gaming video is going to affect a child's privacy especially if it's a non-commentary channel
Not to mention animation
Animation is hard work, taking weeks, months YEARS even, and with these silly rules, they won't earn a single penny for their hard work, please reconsider adding this rule to YouTube as nothing was wrong before, what you are doing is equivalent to blinding a child deafening a child and locking them up in a Tiny room, You are putting them in a small bubble and not letting them have freedom on what they would like to watch, and there is YouTube kids. It's the parents fault for not "Protecting their child" Not content creators. So reconsider this please.

I dont understand why COPPA is applied to you tube. How do you even know if it's a kid or adult watching the video how do you collect data on kids when you dont know if a kid or adult is watching.. Its parents responsibility to ensure their kids are not disclosing any personal info. I have no problem with my child under 13 watching videos on you tube. Teach them to watch not comment, problem solved. I could care less what ads pop up. Ads are on TV and lots of them are geared to kids so kid friendly channels should have ads. There should be parental control on you tube to block kids from commenting then there would be no issues, remember it's the parents responsibility to police what they watch etc. Not the FTC.

I have a YouTube channel that people ages 18-24 watch. No children have ever been on my channel. I hope I don't get effected by the COPPA rule. Please reconsider the rule. I don't have to money to pay any expensive fines and I don't want to risk losing my channel. Thank you for taking the time to read this comment.

Is this seriously it, or is there somewhere that gives more detail on what "visual content" is ? I mean seriously if theres not, then this needs to be taken to court for the ambiguity of it so that we can get clear guidelines down to the letter, cause that's how complex this situation is, you cant possibly think "child-oriented activities " is an acceptable guideline, it's nowhere near clear enough.
I mean I quiet honestly think needing to establish whether your content is for kids or not is ridiculous in the first place, as it's a parents job to make sure they're watching age appropriate stuff and not the creators.

Follow the links in the blog for additional information.

What about travel vlog of a family a mother father and daughter is it under coppa? It is a family oriented channel

i love youtube and i don't want favorite youtubers to go away because they mean so much to me because i don't know what without them. please save them and don't change youtube.

Just because content appeals to children doesn’t mean it’s for children .There are movies , video games and shows that appeal to children because of (for example) the fact that it is animated .It isn’t the creators fault that a child decided to watch their video that isn’t for them unless the title or thumbnail says something like ‘for children , for under 13’s.’ It isn’t the creators fault what they made is acceptable for children and/or is appealing for children ,especially because what topic children like changes. Therefore the creator should not be punished with a fine, nor lower income. Instead the parent should be held more accountable, you shouldn’t have to parent children on youtube.

I have a YouTube channel that is primarily about animation. The rules about animation are confusing.
If the animation has a dark subject matter does it mean that it is "not for kids". What if the FTC mark a video with a dark subject matter as "for kids"?
Are animation memes safe? I'm really scared for the future of my channel.

The FTC is not labeling content on the YouTube platform.

You seriously need to rethink this approach. If only google would make it harder for kids under 13 to actually use and login to youtube, then there would be no problem at all. Now you've only let all content that is considered "for children" to be really hard to find. Now children cannot even search for content that is actually intended for them. All chrilden will simply end up watching more adult themed videos because of this stupid decision. Congratulations. An approach as stupid as this can only come from America. Casper, Denmark

what kids watch should be responsbility of their parents not the fault of the platform or video creators. this is very wrong way to get things solved you ruing the creativity of people that worked too hard to build their channels and passion..kids do watch everything no matter what. small example they watch real garbage trucks not toys but real cars they put away garbage. would you consider this as video kids content?? of-course not.. but here you are kids do watch garbage trucks.. so lets say i create video with real garbage trucks how would i mark this kind of content for kids or not.. so thats an example for you to see that there no real tags whats meant to be for kids,,they do watch everything and this new rules will destroy the whole idea of creativity on you tube

Why are you seeking to penalize crafters who are sharing their art and helping others to learn how to do it. Family friendly channels where homesteaders share their home and families with us and arts & crafts channels that share people's collections and how-to videos on repairing or changing fashion dolls should not be blamed if children watch them...why not use a system of warning parents like movie and tv ratings do now?
Just a thought, but it might save some people a lot of grief and money...please be more plain-spoken with your current guidelines...

How has this not been stricken for vagueness?

My channel is safe for children

I do not have a YouTube channel. But I watch tutorials, music and how to fix stuff videos. I personally think that YouTube is throwing Their content creators under the bus and avoiding their culpability and responsibility to comply with COPPA regulations. Their solution is vague and difficult to follow making the content makers continue on a wing and a prayer

Why not just demand that YouTube/Google comply with the law and stop tracking children, rather than put the onus onto content creators who can't control what is or isn't tracked?

This "made for kids"/"not made for kids" nonsense isn't helping anyone. Let people make content for whoever they want to. Make YouTube/Google be responsible for not tracking kids since they're the ones so hellbent on tracking people in the first place. Content creators in large part just want to make content that people enjoy without the looming spectre of financial ruin for checking a checkbox the wrong way.

Please push YouTube to add a 3rd 'wider audience' option for content posted to the site. "For kids" and "Not for kids" are extremely vague and do not fit most of the content posted to YouTube. I understand this move is to protect children and their privacy but this is hurting so many creators, their livelihoods, their families and in turn their children.
Please also amend your guidelines on what "child directed" content is as this is causing much confusion for YouTube, I have watched countless hours of other creators trying to understand and summarise these policies and they nor myself know if we can continue with our channels due to these changes. Please provide some clarity.

The FTC shared some general rules of thumb in this blog. Unless you’re affirmatively targeting kids, there are many subject matter categories where you don’t have to worry about COPPA. On the other hand, if your content includes traditional children’s pastimes or activities, it may be child-directed. For example, the FTC recently determined that an online dress-up game was child-directed.

The complaint in the YouTube case offers some examples of channels the FTC considered to be directed to children. Many content creators explicitly stated in the “About” section of their YouTube channel that their intended audience was children under 13. Other channels made similar statements in communications with YouTube. Many of the channels featured popular animated children’s programs or showed kids playing with toys or participating in other child-oriented activities. Read pages 10-14 of the YouTube complaint to see the FTC’s analysis in context.

can you lot not ruin youtube please? making it so you must choose if your video is kid friendly or not kid friendly is wrong YouTube creators should be able to do what they want without being scared out of there minds of being fined 4 million for saying there video isn't kid friendly and you lot say it is. Kid friendly content won't even be a thing if you lot do this because they will lose 90% of there revanue so what would be the point in even doing YouTube if you don't even get payed for the effort you put into your video that's kids friendly. Please change this and make it fair for everyone one make it fair for every YouTube content creator

Please look at the blog again. The Rule allows for civil penalties of up to $42,530 per violation, but the FTC considers a number of factors in determining the appropriate amount, including a company’s financial condition and the impact a penalty could have on its ability to stay in business.

1. You do know kids can just lie about their age when they make a YouTube channel. I did when I was 12.

2. If you’re going to apply COPPA to Youtube you might aswell apply COPPA on the entire website. YouTube isn’t the only platform that shows content not decent for kids. Kids are smart and have many many ways of watching videos that’s not COPPA on dozens of other sites and public cinemas. Heck might aswell do Netflix and Disney +.

3. Just separate kid friendly content to YouTube kids and tell all us content creators to make our videos 13+. Instead of crippling the platform. Yh I get it you guys have money and live a unseasoned lifestyle you don’t know what entertainment is I get that.

4. Please reconsider your decision and make adjustments or just terminate Youtube entirely because what’s the point with these rules it’s Too much Youtube is telling us to do.

My content is made of for every one adult and for kids

But...., what about the animators? It makes no sense. The animators doesn't deserve is to be under the "COPPA" thing.. Literally no making sense, all the FAMOUS animators doesn't do, stuff that arent for kids. And some of bad Drawings thats not might be for kids, But the kids won't even understand it. This is the worstest update ever... If they did it for real. I'm going to quit youtube.. And watching youtube..

Youtube,
If you're reading this, well, MANY people will quit because of the upcoming update.. JUST ALREADY STOP THIS PLEASE.

I am a beauty channel and a small channel at that will this affect my channel? I find the rules to be very vague and confusing? I have marked my entire channel as not for children but I use a little animated coffee cup in my introduction? But children under 13 don't wear makeup in my understanding at least? My target audience is ladies and teens and up but are they going to attack me for creating makeup videos? Government shouldn't be controlling homes! I am so concerned about the level of interference as an AMERICAN CITIZEN!

There is all videos can wacth anyone even children there is no any bad thing.thanks

How about video games? Are gameplays of games like fortnite, roblox, minecraft, etc. Considered ‘directed for children?

Ok, specific question:
If I mark a video as “not safe for kids” for the sake of safety, but in fact it would be ok for kids to watch as there is nothing sexual, offensive, etc; am I liable to receive a fine? Ultimately if I’ve marked it as “not safe” even if it is, I’m not subjecting kids to any unsafe content am I? The only negative as far as I can see is that I’m limiting my audience. No one is at risk at all, right?

Please reconsider. I love YouTube more than anything. The penalties for this law is way too extreme. Some new youtubers most likely have the money to pay $42,000 for every video they made. And if you wiped out Google and YouTube you would be taking giant chunks of the internet out. Some people would thrown into chaos. Do you know how many hours people spend on YouTube or how many searches google get a day. I mean a searched this website via GOOGLE! If parents have a problem with YouTube then they should have the option to get YouTube Kids. Seriously, I think you should reconsider. Please, please, please reconsider. I'm begging you.

YouTube Kids is already a thing, and this rule should be taken down. YouTube's content creators shouldn't be responsible for what a child watches, making it unfair. It really is unfair. It's not the creator's fault that a child watches a certain video, it should be the parent's fault at least.

42,000 dollars fine is an excessive and unusual punishment against online content creators on youtube. Punish those who promote scams or those who promote illicit offers. Do not try to censor the internet because of a few bad people. Punish those who deserve to be punished as this act goes against the first amendment. Youtube has created a seperate application called Youtube Kids for children under 13 years of age. Youtube by default is for 13 yearolds and up.

Parents should be more responsible of what their kids watch, we creators want to make content that everyone would enjoy, you should organize your rules better so that people may understand. Creators shouldn't be responsible of what children do without their parents knowing.

Regarding the new guidelines.
Please do some more research on what is considered ‘kid-directed’ versus ‘kid-attractive’ as it is simply too vague.
Defining the exact parameters as to what is considered kid-directed would help a lot. Thank you!!

The complaint in the YouTube case offers some examples of channels the FTC considered to be directed to children. For example, many content creators explicitly stated in the “About” section of their YouTube channel that their intended audience was children under 13. Other channels made similar statements in communications with YouTube. In addition, many of the channels featured popular animated children’s programs or showed kids playing with toys or participating in other child-oriented activities. Some of the channel owners also enabled settings that made their content appear when users searched for the names of popular toys or animated characters. Read pages 10-14 of the YouTube complaint to see the FTC’s analysis in context.

FTC your rules and regulations do protect us but this COPPA act could mean the end for many of these people’s childhoods that you are trying to protect it not asking to get rid of the act for good but change the rules-thank you in advance

I don't understand why we cannot do a sort of rating system like what we have with movies! This proposition in my opinion is too vague and will in the end be a detriment to creator and also pushing children to find a different platform to watch the things they like resulting in the child finding unsafe sites to be on. Please consider postponing this till we have more details and a better plan and system. Thank you for your time.

I am currently going through all my videos now. I am a crafter and also show recipes on my channel. Some of the things I craft such as my recent Advent calendar can be made for children and adults alike. Yes I made it for my grandchildren but I dont feel the content is made for children. I would never hand a child a hot glue gun to use, for instance. Do I have to list that video as made for children when my intention was to make it strictly for adults?? I'm confused since in my crafts I use items to transform them into other things for Adults.

Setting your audience setting shouldnt be where your monetization gets demonized. Also having a mixed audience option would help and save many channels that adults and kids love.

I strongly suspect that the original purpose for this new version of COPPA is to give the FTC massive censorship powers over the internet. If that werent the case they would be putting the liability on parents or platforms to protect children from exposure to adult content instead of on individual content creators. Whoever was able to push through the extra clearer standards described in the above article in order to help protect content creators despite opposition is a hero and I salute them, whoever they are. Thank you so much and keep up the good work!

First of all, I’m all for protecting my kids but it’s not majority the responsibility of content creators to do this, it’s mine! Parents need to work harder at being stronger “guardians” for their children like enforcing restrictions and screen time while they’re super young, children understanding that they are not the boss of themselves and parents taking control and full responsibility as they should of their own children. I believe that the world has a responsibility to protect children...I do...laws should come into play and punishment should fit the crime but the rearing of children starts at home with the 2 people who decided to have children. Now that those 2 or 1 person has children and start off not wanting anyone to tell them how to raise their kids are some of these parents who want to control everyone else because they can’t control their kids now!!!

Secondly, I’m a crafter who has content on YouTube that is and never has been geared towards children. I do not believe that if I share how I made Hello Kitty invitations for a friend that I should or my content fall under COPPA. This isn't right to lump my content under something that has been geared towards adults which all of my content is by the way. I made a video of a scrapbook layout I made of my daughter using a “back to school” themed paper....again geared towards parents and sharing my ideas of how to preserve a memory but using child like theme products. How and why is this something that would fall under COPPA?

Please, we shouldn’t be punished for something a lot of us aren’t doing. Make it work for everyone involved! Thanks

This rule is way to vague and is something that deserves clarification and specifics. There needs to be an allowance for content creator to be creative without being penalized for it!

Why not allow children to sign up with a special kids account that parents have to create, then treat kids differently than adults based on age, not content? Features that we don’t want taken away for ALL users include subscriptions and comments. Very few channels have 90%+ kids, and most have both. The logic of the proposed solution is baffling.

I fail to see how under the CFR a content provider meets the definition of "operator." The definition specifically applies to those who collect personal information. While YouTube and other platforms may collect such information from the content provider's channel, the content provider does not collect that information. You can please identify the provision under the statue that is being interpreted as implicating content providers as operators.

The term "operator" is defined in the Definitions of the Children’s Online Privacy Protection Act. Here is a part of the definition of operator: 

The term "operator"-

(A) means any person who operates a website located on the Internet or an online service and who collects or maintains personal information from or about the users of or visitors to such website or online service, or on whose behalf such information is collected or maintained, where such website or online service is operated for commercial purposes, including any person offering products or services for sale through that website or online service, involving commerce- [ go to the link to read the rest of the definition]

I feel that COPPA is overreaching. I don't think the government should be parenting. YouTube said 13 and older to go on this site, why don't you go after all those parents and toddlers who broke the rules? That would be ridiculous, because we all know parents gave nonverbal consent when they handed a tablet or phone to their child AND logged in for them ect. Why is that not enough? Why can't you let parents decide what their own children do? Parents are adults and they provide for their children AND through taxes provide for the government as well, they should be allowed to decide what they give their kids access to without having to jump through the hoops COPPA lists to get parental consent.
ALSO I find it VERY insulting and prejudicial for the government to tell me that everything I enjoy as a productive tax paying ADULT is "children's content". You are implying that what I like is not for me but only for children!
I enjoy everything on your really long list of very very vague "children's content" Because I like crafts and toy collecting according to you I'm a child.
I feel as though COPPA hurts children more than it helps because anyone in their right mind will stop making family friendly content so as to not be attacked by the FTC. But children and teens will continue to go on the internet no matter what the government says or does so they will then be more exposed to inappropriate content because of COPPAs broad and strict rules.
Plus, once children turn 13 they will be tracked until they die so what really did COPPA do? Postpone the inevitable a year? Two years? In the end it will have been for nothing.
Statistically the people most likely to hurt a child physically are people that child actually knows in their real life and not someone online. So COPPA doesn't help the majority of children. But it does A LOT of HARM to a lot of children and teens and adults by taking away incentives to make family friendly content online. The world and the US is a better place with more family friendly content online. And it is ignorant to think that people will continue to make the same quantity of family friendly content online with harsh COPPA laws looming to penalize around every corner.
After January if I want to watch a craft video about clay sculpting with bright fun colors on YouTube I may not be able to find or watch or save that on YouTube, if I want to make a family friendly video to share with all ages I probably won't because I don't want the COPPA police to come fine me money I don't have for trying to put more good out into the world.

I find it VERY insulting and prejudicial for the government to tell me that everything I enjoy as a productive tax paying ADULT is "children's content". You are implying that what I like is not for me but only for children!
I enjoy everything on your really long list of very very vague "children's content" Because I like crafts and toy collecting according to you I'm a child.

I feel as though COPPA hurts children more than it helps because anyone in their right mind will stop making family friendly content so as to not be attacked by the FTC. But children and teens will continue to go on the internet no matter what the government says or does so they will then be more exposed to inappropriate content because of COPPAs broad and strict rules.
Plus, once children turn 13 they will be tracked until they die so what really did COPPA do? Postpone the inevitable a year? Two years? In the end it will have been for nothing.

Statistically the people most likely to hurt a child physically are people that child actually knows in their real life and not someone online. So COPPA doesn't help the majority of children. But it does A LOT of HARM to a lot of children and teens and adults by taking away incentives to make family friendly content online. The world and the US is a better place with more family friendly content online. And it is ignorant to think that people will continue to make the same quantity of family friendly content online with harsh COPPA laws looming to penalize around every corner.

After January if I want to watch a craft video about clay sculpting with bright fun colors on YouTube I may not be able to find or watch or save that on YouTube, if I want to make a family friendly video to share with all ages I probably won't because I don't want the COPPA police to come fine me money I don't have for trying to put more good out into the world.

Pages

Add new comment

Comment Policy

Privacy Act Statement

It is your choice whether to submit a comment. If you do, you must create a user name, or we will not post your comment. The Federal Trade Commission Act authorizes this information collection for purposes of managing online comments. Comments and user names are part of the Federal Trade Commission’s (FTC) public records system (PDF), and user names also are part of the FTC’s computer user records system (PDF). We may routinely use these records as described in the FTC’s Privacy Act system notices. For more information on how the FTC handles information that we collect, please read our privacy policy.