FTC: Consumer Privacy Comments Concerning The Ashley Grayson Literary Agency--P954807
ASHLEY GRAYSON Date: June 4, 1997 To: Toby Milgrom Levin, Federal Trade Commission At: (202)326-3259 Pages: 11 (inc. this first page) Dear Ms. Levin: Here is our response for the Workshop on Consumer Privacy on the Global Information Infrastructure, which is coming up. We plan to attend Session Three. Since Session Three is currently scheduled over two days (June 12 and 13) we will call you to get more information about the planned schedule of presentations. If you have any questions for us, we will be out of the office, but we will be checking with our office for messages, and will return your call as soon as we can. Regards, Carolyn Grayson for AG ASHLEY GRAYSON June 4, 1997 Robert Pitofsky Dear Chairman Pitofsky: We are writing to follow up the Public Workshop on Consumer Privacy on the Global Information Infrastructure that was field in June, 1996, and to offer our comments for the Workshop which will be held in June, 1997. We are representing A Girl's World (www.agirlsworld.com) and are responding regarding the subject of children and privacy online. We fully agree with the Commission and previous workshop participants that (1) children are a special audience; (2) information collection from children raises special concerns; (3) there is a need for some degree of notice to parents of Web sites' information practices; and (4) parents need to have some level of control over the collection of their children's Information. We have read the Guidelines proposed by the Center for Media Education, as well as the response from the Ingenius group. We agree with the Ingenius group that while the CME's guidelines are useful for discussion, they are excessively restrictive. We support the Ingenius group's suggestions for self-regulation as outlined in their proposal. We agree with the CME that parental consent should be obtained before children give out personally identifiable information. But we seem to have some disagreement with the CME as to what constitutes personally identifiable information. We believe that first name, first initial of last name (if collected), city, state, and e-mail address are not personally identifiable pieces of information. While parents should be aware of and consent to their children's use of Internet Web sites that collect such data, to mandate a verifiable parent's permission be obtained before Cindy from St. Louis posts that her favorite flavor is strawberry seems to us to overmanage the key qualities of children's interaction on the Web. We are also responding to the Center for Media Education's letter to your office, dated November 25, 1996. We note that in their letter of November 25, 1996, the CME specifically mentions our client, A Girl's World, as being a site "that collects personally identifiable information without any disclosure." Further, the CME writes in their letter of that date: "In order to join the club, a girl must submit her first name, grade, age, state, country, birthday, and e-mail address. She is also asked personal questions such as 'what kind of pet do you have?, 'what books do you read?, and 'what do you like to do to have fun?'" We must take this forum to respond that the CME's charges as regards the A Girl's World site are false and their allegations mistaken. This goes again to the issue of what is personally identifiable information. We do not consider any of the information we collect on that screen as personally identifiable. Becoming A Girl's World club member is completely optional, all personal identifiers are removed, and parental consent and participation is encouraged via this notice on our club member page: A Note to Girls (And their Parents) A Girl's World Online ClubhouseTM is a privately funded edutainment provided on the Internet for the purpose of providing a safe place for girls aged 7-14 to experience the net and make friends. This statement of purpose is clearly expressed on the site. At A Girl's World, every effort is made to ensure the safety and privacy of participants. All personal Identifiers: last name, city, school, etc. are removed from materials girls send us before they are posted, A Girl's World provides the only free Pen Pal Club for girls which shields girls' real e-mail addresses. We are a registered "safe-site" by a number of other "non-profit" organizations whose goal is the same as ours: to protect girls and children. The CME also charges that A Girl's World must be "seeking funding through the sale of advertising or demographic information collected at the site . . . [but] does not indicate why A Girl's World is seeking out these companies. As the Ingenius group stated in their proposal, "Advertisements play an essential role in funding the substantial costs of building and maintaining a World Wide Web site." While A Girl's World may be seeking sponsors or advertisers, we have no personally identifiable Information to sell them. The texts which follow, of A Girl's World Welcome to A Girl's World page, and A Girl's World Welcome to the Club! page demonstrate clearly the care A Girl's World takes to ensure safety and privacy for participants on our site. We feel that the CME has not acted responsibly in citing our site for privacy violations, and are especially concerned that their misleading and mistaken allegations are carrying over into other media. In summation, therefore, we at A Girl's World are very aware and very concerned about privacy issues in collecting information online from children, and we, ourselves, take great care in assuring the privacy and safety of our participants. The Center for Media Education style themselves as a concerned watchdog group; but what concerns us most is that they call attention to problems (such as our site), where, in fact, none exist. Specifically, the CME style themselves as morally superior to the organizations who are trying to provide entertainment for children and accuse A Girls World In particular of both actions and motivations that they never investigated and which are not true. In addition to writing unjustified accusations to the FTC about A Girl's World they have repeatedly circulated the text of their FTC letter to the press with the presumption of their moral virtue and our guilt by accusation. We will not consent to being judged by press release and used as the example by which a government body is pushed into establishing regulations to control behavior that we never engaged in. We do invite the Commission to consider how we have been able to provide an attractive, safe environment for kids prior to any rulemaking. Submitted and signed by, Ashley Grayson attachments:
[Image] About A Girl's World Table of Contents
-------------------------------------------------------------------------- Welcome to "A Girl's World Online Clubhouse ®", the biggest, the best and the very first on-line interactive magazine for girls on the World Wide Web. Your hosts-- "A Girl's World's" fabulous founding four, Amy, Geri, Rachel, and Tessa -- invite girls to explore each of their rooms in the clubhouse. Their motto? Girls are cool! "A Girl's World" premiered in May of 1996
with these goals, to give girls the world over a safe
place on the Internet to make new friends, explore their
futures, dream big dreams and be creative and
adventurous. It's fun. It's free. And it's brought to you
every day by a bunch of volunteers, grownups and girls
who give time to the clubhouse because they truly believe
being a girl is something to celebrate.
Our number one concern at A Girl's World Online Clubhouse is safety and privacy. Here's what some of our reviewers have been saying about us: In May's Consumer Reports "Four Ways the Web
Serves Children Well," A Girl's World's Penpal
Spectacular is recommended for our "better
security" because "users communicate through
numbers similar to a post-office box, so they don't have
to disclose their e-mail address." Too Cool Schoolhouse said, "A Girl's World emphasizes safety first, All girls who contribute to the magazine are protected by having their identifying information removed, and all email responses are screened by hand before being posted to keep the site safe as well as fun. A Girl's World Online Clubhouse is an exceptional site that celebrates being a girl. An inspiring, educational, and great place for girls to hang out, share, and contribute." Universal Syndicate's 4Kids.org called A Girl's World "an incredible online experience. This home age is hopping, and you don't have to wear a dress-this place is for girls of the '90s! There is so much to do, you could stay for days." San Diego Union Tribune gave our site a "Spectacular, Five Star" rating, saying that we're "the best site on the internet for girls." Computer Currents Interactive chose us for its Link of the Week for out "originality, content and quality". Their review noted 'A Girl's World will make girls feel at home in cyberspace." Facts About A Girl's World Safety: We do everything we can to shield girls' identities on the web. All the girls who contribute or "host" areas on out site have any information that would identify them altered to protect them. Personal identifiers last name, etc. are removed from everything that is posted on the site to protect girls' privacy. We even brush out logos on pictures, etc. for our "Featured Members" area. Information Use: All information posted by girls on this site is used for educational and entertainment purposes only. We don't sell or give information out to anyone else. Screening: All clubmail and responses are screened by hand before being posted to keep the site fun and safe. It takes longer, but we believe it's important to remove last names, addresses, and other personally identifying information about girls from messages before they are posted. We have rules about girls respecting each other when posting materials. Since this is a "girls only" club, we also screen out contributions from guys. Sorry guys, girls only. Joining the Club: Girls of every age, from every country are welcome in our clubhouse. Unlike many online kids clubs, it is not necessary to join our club in order to explore and enjoy it. The only "plus" girls get by filling out the "Join Us" form is a newsletter if they choose to receive it (and all email addresses are kept private) and a posting in our Members Only area. Members Only: This area gives girls the opportunity to share what they think with other girls from over 180 countries. One of the goals of the club is to promote respect, tolerance and multiculturalism. Girls can find out what girls from other countries are like, and what other girls their ages are like. The purpose of our Members Only area is to break down barriers between girls of every age, color, creed or country. Target Audience: Our site is international in its scope and designed for girls between the ages of 7-14. Girls who are younger and older often join us, and they are welcome. We have also created articles, resources and features for parents and teachers and girls to enjoy together. That's because we think family activities are important. E-Mail Addresses: We do send out an online email newsletter to girls who request it by signing up with their email address in our "Join Us" form. Email addresses are only used for trial purpose, and we don't give them out to anyone. Ever. Even our penpal area has been designed so that girls don't give out their email number to anyone except our webmaster, who keeps it a secret. We don't read or track girls' penpal mail. Everything is kept private. Who's Here? The girls Joining the clubhouse live all across the United States and Canada, followed by Australia, Malaysia, Japan, the UK, South Korea, Brazil, Sweden, and more than 90 other countries. Now that's cool! What's It About? The grownups' goal for "A Girl's World" is to inspire, educate and entertain girls. We want girls to grow up knowing they are valued, feeling confident, self-reliant, and good about who they are. Everything in "A Girl's World" works towards that end. What's different about "A Girl's World"? This is the very first interactive environment written by girls as well as for girls, "A Girl's World Online Clubhouse ®" is the space where girls run the place! That means we have a team of volunteers, girls 7-17 who meet regularly to tell the editors what girls would like to see, do and be. Girls online are invited to join the fun by making their suggestions for the next issue. They're invited to write articles and conduct interviews too. Girl reporters conduct role model interviews, covering women who are leaders in the fields of science and technology, business and the arts. When we can, we invite girls to submit their questions to a clubhouse guest, so that everyone can participate in the interview process. So, What's In Here? Cool Careers: Tessa sponsors Trailblazers, Amy has Wildside, and Rachel invites girls to Hang With special guests. Girls share fun activities too, like games, holiday survival tips, and Geri's Country Kitchen recipes to try every day. We've also programmed the first, free pen pal area on the web, Want to make new friends but you don't want to give out your e-mail address? This is the place! In Geri's Pen Pal Spectacular, thousands and thousands of girls from more than 90 countries around the world are waiting to write to you! Right now, there's an interactive "Magic Story" game in "Giggles" where girls can create their own adventure. There's crafts for girls and by girls in "Quick Crafts". Girls have a chance to share what they think with other girls as they answer the Featured Member's Question every month or contribute to Teen-Talk's Glow!". Girls share the joy and difficulties of friendship and give each other advice in "Between Friends". Entertainment news and reviews happens on "Beat Street" in Rachel's room. There's special events and themed activities for girls in Amy's Pajama Party. Girls can find special games, sleepover suggestions, romantic movie ideas and fun stuff to do in Sockhop's Romp. Do-lt-Yourselfers will enjoy I/O's "Need to Know" area. Our club even has an online service project called Helping Hands . For girls who enjoy quizzes, there's Tessa's Quiz Cafe! New games and activities are being added all the time. How Do I join the Fun? It's easy. Step into "A Girl's World Online Clubhouse ®" with your girlfriend or parent or teacher today! And help us spread the word about a site that's a real self-esteem builder for the women of tomorrow. --------------------------------------------- A Girl's World Online Clubhouse ® Recent Awards
----------------------------------------------------------------------- For more information, Please contact: A Girl's World Productions ---------------------------------------------------------------------- [Clubhouse] [Mail Box] [FAQ] --------------------------------------------------------------------- Copyright © 1994-1997 by Karen E. Willson [Image] Hi! Welcome to the Club!
Join the Fun! Ready to share what you like and think with girls around the world? Fill out this form. Then, check back later in Members Only to see your answers - and meet the coolest girls in the world - our club members! P.S. Don't have a pet or a question for the girls of the world? Leave any line empty that you don't. want to answer. See you in the club!
Things sure have changed since our moms and grandmoms were girls. So...what's cool about being a girl today? What's the one question you'd really like all the other girls in the world to answer? ----------------------------------------------------------------------------- All materials submitted to "A Girl's World" become the property of "A Girl's World Online Clubhouse." ----------------------------------------------------------------------------- [Image] [Image] [Image] ------------------------------------------------------------------ Copyright © 1994-1997 by Karen E. Willson |