16 CFR Part 312; Children’s Online Privacy Protection Rule Review; Project No. P104503
As a concerned parent and education program evaluator, I am writing in strong support of significant changes in regulations in order to restrict online business from tracking and targeting children with advertising. As a parent, I make great efforts to restrict and supervise my children's use of online resources, but am recognizing that web-based business has an unrestricted arsenal of tools to access and utilize children's personal information without parental consent or knowledge. The fact that the COPPA rule has not been revised in 10 years is unacceptable given how much more sophisticated the technologies and techniques that have evolved to target children in ways that parents and school staff can not control. Given the laxity of the regulations, parents have little means to protect children from many of the current risks of the online experience, short of keeping their children off of the Internet. But when schools are using the Internet for educational purposes and asking children to access websites at home, complete avoidance is not feasible. Internet advertisers use behavioral targeting and one-to-one marketing strategies on children without parental consent. The loopholes in the current version of the COPPA Rule make it easier for advertisers to do this. Parents would like to supervise what their children are doing online, but find it difficult to do so because privacy and advertising policy notices are hard to find and impossible to understand. Advertisers and other website operators use increasingly sophisticated technologies to identify individuals. The COPPA Rule should be updated to reflect the reality that “personally identifiable information” about children is an expanding category. In particular, the COPPA Rule should clarify that operators must ask parents’ permission before they collect: --Children’s IP addresses --Children’s geolocation information --Children’s screen and user names --Photographs and videos of children I strongly urge the FTC to update the COPPA Rule quickly and effectively to ensure that COPPA remains an effective tool for protecting children and supporting healthy families.