16 CFR Part 312; Children’s Online Privacy Protection Rule Review; Project No. P104503 #00013 

Submission Number:
Douglas Himan
Initiative Name:
16 CFR Part 312; Children’s Online Privacy Protection Rule Review; Project No. P104503
As an executive of a small social networking site for kids ages 8-14, I'd like to share some very interesting findings we have experienced with our users. As you know, parents and special interest groups all have expressed deep concerns about privacy and protection for their children. As a father of two, I get it. For every 1000 parents that sign up to our website, only 7 parents use the permission controls setup for their kids. All other parent users ignore the permissions. We have several theories as to why: 1) parents trust their kids, 2) parents don't want to be bothered or learn something new, and 3) they have the ability to see what their kids do online in real time or via nightly reports. We have found kids are a very demanding set of users. Even though they understand, when taught, online safety, they follow rules, however, they don't want to wait for their parents. Kids want instant access. Understanding that kids are impatient, especially teenagers, kids will gravitate to other websites, like Facebook, to get what they want if we create even more roadblocks. Even though sites claim to be COPPA compliant, their systems are on an honor system. It's based on what the user tells the website. Therefore, if you tell the system you are over the age of 14, you are be treated like an adult. To stop this, COPPA would need to require "all sites" to verify one's id. This would be outside the scope of COPPA. If you want to protect kids, increasing registration measures on kid websites will simply drive more kids to adult websites where kids can avoid extra security measures and get instant access. The existing registration requirements today are considered burdensome by many. We see kids going to adult social networking sites on a daily basis. To help protect kids, the issue is not to make the registration requirements more difficult, but to increase the level of security and access to information for parents once they become registered users. As a kids social networking company, we need to ensure parents have access to kid accounts and receive timely alerts regarding their kids. Parents should have the option of setting controls. Companies of kid social networking sites should be monitored by company staff. Adult users should be restricted to making friends with kids without adult approval. Companies should not track kid users for controlled marketing. On adult sites, parents are blocked from having access to kid accounts. Adult sites allow kids to get access via an honor system. Again, kids are taking the path of lease resistance. We highly recommend COPPA focus on access and control of information and not simply the registration process. More control with registration will simply drive kid users to adult sites, with little regulations, defeating the purpose of providing a safe online environment for kids. If you have any questions, I can be reached at