| Comment Number: | 514511-00090 |
| Received: | 2/14/2005 9:47:19 PM |
| Organization: | Gestweb S.p.a. |
| Commenter: | Julie Duncan |
| State: | CA |
| Agency: | Federal Trade Commission |
| Rule: | Notice of Proposed Rulemaking, Request for Comment |
| Docket ID: | 3084-AB00 |
| No Attachments |
Comments:
Thank you for allowing us to comment on the proposal to amend the Childrens Online Privacy Protection Rule. Communicating to minors is not easy, considering the fact that every human being under the age of eighteen years is legally a minor. Unlike television, the World Wide Web is not a passive enjoyment phenomenon, but an interactive jungle with many paths and obstacles, some of which lead to the big bad wolf disguised as an anonymous friend. There needs to be a KEY to open and to close certain doors that are not suitable for minors. There is a solution which allows children the right to enjoy their youthful curiosity with innocence while not violating the freedom of speech available to the adult world. The solution is called childKEY. childKEY technology was created by Gestweb S.p.a. in conjunction with Onlus Safety World Wide Web Foundation (SWWW) and represents the only true design which satisfies the premise of differentiated web surfing. The concept of the childKEY technology is based on its ability to make a link between the requested web page and the age of the user who makes the request. To do this, the users profile must be recognized when the connection to the internet is made, or before surfing begins. This is made possible through the use of a password prompt that must be completed when an internet connection request is submitted. A simple one time task originated by an adult. The action of identification carried out by the new childKEY Network performs in combination with internet providers who have by contract signed on with the childKEY service. Utilizing this technology, childKEY can provide differentiated web-surfing experiences for both adults and minors based on the login that is entered by the user. When a password is entered that corresponds with a minor, the childKEY authenticator routes the connection through assisted surfing, activating Age Sender, Time Limit Control and Total Privacy, as well as, parsing functions and Text Analysis. Age Sender, allows remote servers to recognize the age of the connected user (sole worldwide technology) therefore making providers of content and web hosts legally accountable. Adapting themselves to the childKEY technology, web site managers, can easily categorize their work by adding a simple declaration to their web pages (metadata childKEY) concerning the content of their website. Widespread use of this technology will change the way Providers, Search Engines and online content suppliers operate, thus conforming to the criteria of their responsibilities towards minors as well as to Ashcroft v ACLU, USSC #03-218. Differentiated Web Surfing, a proactive approach, is the only measure of its kind available today. Gestweb has also created KEYstudent, an integrated system for schools, libraries and youth centers where the need to protect young web surfers is also a concern. KEYstudent can be applied to the schools network and locks out, among other things, access to inappropriate internet pages. It is not necessary to install any software on the PC and it also provides a simple configuration Interface for the system administrator. The goal of childKEY technology is to protect the childs right to privacy and ensure correct processing of personal data, in addition to providing appropriate protection against the risk of minors coming into contact with content that is unlawful or harmful to their development. The Foundation, SWWW is determined to assist internet users in accordance with national and international law, while providing equal opportunities for accessing the resources of information technology and promoting a secure access to the jungle. The childKEY technology has proved to be very successful and well received in the European community. For additional information, please contact U.S. representatives of Gestweb S.p.a. Julie Duncan, Attorney,