The Early Years Institute
16 CFR Part 312; Children’s Online Privacy Protection Rule Review; Project No. P104503
I am an educator concerned that the COPPA Rule which needs significant updating given the dramatic change in the number of hours children spend with various screen media and the fact that the rules haven't changed in ten years. We work with teachers in preschools and elementary schools and find them alarmed at the lack of social skills and impulse control among children entering their classes. Some blame parents, but many others realize that even with vigilant parents, they are no able to monitor their children's screen time activities or limit the amount of advertising and marketing directed to their children. Parents cannot protect their children from too much media and advertising without the help of the FTC. There has been widespread concern about this issue for many years and a growing number of problems resulting from our inaction. Please eliminate the loopholes in the current version of the COPPA Rule that make it easier for advertisers to do market to children. The COPPA Rule should be updated to reflect the reality that “personally identifiable information” about children is an expanding category. In particular,operators should have to ask parents’ permission before they collect information about children's IP addresses, home address, screen name, or photographs and videos. I urge the FTC to update the COPPA Rule as soon as possible to ensure that COPPA remains an effective tool for protecting children and assisting parents.