16 CFR Part 312; Children’s Online Privacy Protection Rule Review; Project No. P104503 #00030 

Submission Number:
Christopher Ferguson
Texas A&M International University
Initiative Name:
16 CFR Part 312; Children’s Online Privacy Protection Rule Review; Project No. P104503
Dear FTC: Although I understand the current rules are well intended and address legitimate privacy concerns, an less convinced that the proposed changes are a positive means for addressing these issues. I write both as a psychologist and researcher who has studied extensively the interaction between technology and human behavior, as well as the parent of an 8-year-old child. I express the concern here that proposed changes and rules are being offered before we fully understand the issues at hand and that these may be more onerous and damaging than the actual "harm" they are meant to avoid. The issue of privacy on the internet is an important one, don't get me wrong. To the extent that social networking sites are violating privavy, whether of children or adults, it is important that society is informed of these issues. However we also know government has a history of rushing legislation to "protect the children" even when such legislation is misinformed or is prompted by "moral panic" rather than good science. Witness for instance various efforts to "shield" children from violent video games, despite that ultimately it has turned out that claims of "harm" due to such content were mistaken. Pursuing legislation (and bad science) ultimately did more harm to the credibility of government and social science than any good it ever did. Some of the proposed rules, regarding parental consent and such, appear to me to be rather onerous and unhelpful. Certainly as a parent I wish to be informed about legitimate privacy issues that may inform my decisions when monitoring my child's internet use. However having to go through great lengths to prove my consent to allow my child to use the internet is unnecessarily burdonsome and an unwanted intrusion of government into my family life. I have full confidence in my ability to supervise my child and I do not need or want the government's assistance in this. As a researcher I see little evidence offered that such efforts will be helpful to the welfare of children and, by contrast, may actually cut children off from legitimate and educational opportunities on social networking sites. Research came out this week finding that many parents already circumvent the "protections" currently in place, let alone any new ones, suggesting that these "protections" are largely unwanted, viewed as unhelpful and unnecessarily burdensome by the majority of parents. Thus I urge the FTC to reconsider the proposed rules which are likely inefffectual and harmful rather than helpful. I believe attention should be focused on education and "getting the word out" about legitimate privacy and safety concerns, not government intrusion in parenting decisions. Repectfully, Christopher J. Ferguson, Ph.D. Texas A&M International University