2010 Children's Online Privacy Protection Act Rule Review #547597-00030 

Submission Number:
Larry Magid
Initiative Name:
2010 Children's Online Privacy Protection Act Rule Review
ConnectSafely applauds the Federal Trade Commission for taking a fresh look at the Children’s Online Privacy Protection Act (COPPA). While we fully understand and endorse the need to protect the privacy of young children, we are concerned about possible unintended consequences of COPPA as it applies to “Web 2.0” interactive services. Today’s interactive web provides an enormous opportunity for young people to communicate with each other and with trusted adults via both mobile and fixed social networking services. Millions of teenagers have been using services like MySpace and Facebook for the past several years and, despite some issues, the vast majority of them have done so safely and productively. Partially because of provisions in the existing COPPA legislation, these sites are off-limits to youth under 13. However, a great many pre-teens are using these sites despite the companies’ terms of service. For example, a recent survey conducted by Harris Interactive (commissioned by McAfee) found that 37% of youth between the ages of 10 and 12 have an account on Facebook. Fifty percent have an account with some social networking service. (http://safekids.com/mcafee_harris.pdf) It is not clear to us whether any harm is coming to pre-teens as a result of their use of these services but we are bothered that they are, in a sense, being encouraged to lie about their date of birth to sign-up. We are also concerned that because pre-teens are technically not allowed on these services, the operators of the services are less inclined to provide safety and privacy tools aimed at this age group. We urge the FTC to put some thought into updating COPPA to reflect the realities of young people’s use of the Web, as it has evolved considerably since COPPA was first enacted near the end of the 20th century. We certainly don’t want to see teenagers banned from accessing these services and we would like to see ways to allow access to younger children with appropriate educational materials and protection. We are also concerned about the widespread misconception that COPPA is an "online safety law," which could cause parents to worry about the safety of children who use social networking sites. In conjunction with the forthcoming update of COPPA, we encourage the FTC to educate the public as to the law's scope and purpose. Larry Magid & Anne Collier Co-directors, ConnectSafely.org