Speechly Bircham LLP
Outside the United States
16 CFR Part 312; Children’s Online Privacy Protection Rule Review; Project No. P104503
Speechly Bircham is an international law firm with a recognised expertise in data protection and is the founder of The i in online Limited which is a UK not for profit that provides training and education to children, parents and teachers about data protection and the management of privacy and reputation online. We welcome the Proposed Rule and Request for Public Comments and in particular the concerns of the FTC that COPPA should continue to be relevant and appropriate to the protection of the rights of children. Our work in the UK with support of the Information Commissioner's Office has given us particular insight into the attitudes of children to privacy and data protection. Our research has been published and is available at www.theiinonline.org With many children as young as 8 years old regularly subscribing to social networks and online massive multiplayer games that are clearly intended for an older audience we believe that not only must website and service providers take responsibility for consent and age verification but as importantly there should be more provision of training and education in schools so that children become aware of data privacy and how to manage their reputation and privacy online. Whilst this is not an aspect of COPPA we trust that FTC will consider this?