i-SAFE, Inc. Application for Safe Harbor #546345-00010

Submission Number:
Rebecca Newton
Mind Candy Ltd.
Initiative Name:
i-SAFE, Inc. Application for Safe Harbor
To whom it may concern: I would like to express my concerns with the I-Safe application for Safe Harbor provider status. As the Chief Community & Safety Officer for Mind Candy Ltd. I am responsible for ensuring online safety and proper marketing & advertising practices for 15 million registered users from around the world. A significant number of those 15 million registered users are under 13. It is my business and privilege to protect and educate young people in the online world. I have been in this business since 1994 and recruited, trained and managed literally thousands of online community professionals. COPPA compliance and Safe Harbor certification is first and foremost on the minds of every serious online community professional who works with children. My first concern is that by adding a new organization to the Safe Harbor certified group, it could very well slow down or hinder the review process. Having worked with 3 of the 4 certified Safe Harbor certified organizations, I understand the intense and serious nature of Safe Harbor site review and compliance. At this crucial time of COPPA regulation review, I urge you to consider the timing of I-Safe's application as potentially problematic. Safe Harbor certification is a complicated process and is now more than ever critical to the future of young people, parents, teachers, and online businesses & non-profit organizations. I believe the review process will be further complicated by adding I-Safe. Their getting up to speed with the issues at hand could significantly slow down the review process. Industry professionals are hoping for the opposite in this year's review. My second concern is in reference to the I-Safe site registration process. When evaluating I-Safe's site, the organization appears to be non-compliant with my understanding of the COPPA compliance requirements. Regardless of their non-profit status, I would expect a Safe Harbor applicant to lead by example. I appreciate the opportunity to address my concerns and thank you for your time and consideration. Respectfully, Rebecca Newton Chief Community & Safety Officer (CCSO) Mind Candy/MoshiMonsters.com