2010 Children's Online Privacy Protection Act Rule Review
After reviewing FTC (DOCID: fr05ap10-24) Request for Public Comment on the Federal Trade Commission's Implementation of the Children's Online Privacy Protection Rule, I have submitted the following comments on this matter. I do support revision of the Children's Online Privacy Protection Rule, but only in specific areas. I have listed some areas I feel are sufficient and which need improvement. It is my opinion that there is a continuing need for the Rule as currently promulgated in most areas, and the Rule is still as effective as it needs to be in general. As mentioned in the text, the internet is being accessed via mobile phones and I believe that the mobile issue can be resolved if parents are more vigilant about controlling access to a phone which has this capability. I do not agree with a child having a cell phone, but if they must have one, get a phone that does not access the internet. I feel the effect this Rule has had on children and parents to this point are positive due to the limitation of data collection from children specifically. Of course some parents may see it as an inconvenience, but in the long run it’s worth it. Of course if any changes are made to the rule, I would prefer to see no data collecting at all from minors. The definitions set forth in Section 312.2 of the Rule does accomplish COPPA's goal of protecting children's online privacy and safety in my opinion. It’s now the parent’s information which is at risk due to use of credit card information. The specific term “Internet” is sufficient as well, whether it is on a computer or on a phone, it’s still the internet and is still accessed through a browser. I believe the consent requirement of Section 312.5 has been effective in protecting my children's online privacy and safety up to this point, but I feel it does need to be revised. I have yet to see a permission slip to send in, or a toll free number to call. It seems most all the sites are more than happy to use the credit card method of verification. This is the least appealing to the card holder due to identity theft and credit fraud. I believe the permission slip would be the most effective way to gain consent as long as the slip contains contact information for the parent and the company is required to contact the parent via phone. The parent should have the option of scanning the document and e-mailing it to the company, or posting to a secure database or website. Thank you for the opportunity to voice my opinions in this matter.