16 CFR Part 312: Children’s Online Privacy Protection Rule Safe Harbor Proposed Self-Regulatory Guidelines; the Entertainment Software Rating Board’s COPPA Safe Harbor Program Application to Modify Program Requirements # 00003

Submission Number:
00003
Commenter:
Christina Aguirre
State:
California
Initiative Name:
16 CFR Part 312: Children’s Online Privacy Protection Rule Safe Harbor Proposed Self-Regulatory Guidelines; the Entertainment Software Rating Board’s COPPA Safe Harbor Program Application to Modify Program Requirements
Matter Number:

P024526

As a mother and graduate student, it is important to protect the rights and privacy of young children. The rapidly changing technology makes it essential to review the terms of programs such as Children's Online Privacy Protection Act (COPPA). A general comment would be for the Children's Online Privacy Protection Act (COPPA) and other programs such as the Safe Harbor Program be reviewed on an annual basis with the rapidly changing technology it is important to make sure such policies are up to date. My only comment to all of the proposed changes would be; in section IV.C of the proposed Requirements, we have clarified that the link to a Kids Privacy Statement must be prominent and clearly labeled, and we have added the requirement for online apps that a link to the privacy statement be available in the app store prior to download. My proposed change would be to make requirements such a font size and color, the ability to have the statement catch the users eye with bold colors and font. Many times the Privacy Statements are hidden and overlooked because of the color and font size.