| Comment Number: | EREG-000002 |
| Received: | 1/29/2005 8:00:00 AM |
| Organization: | |
| Commenter: | Belinda Brewer |
| State: | CA |
| Agency: | Federal Trade Commission |
| Rule: | Notice of Proposed Rulemaking, Request for Comment |
| Docket ID: | 3084-AB00 |
| No Attachments |
Comments:
January 29, 2005 Secretary Federal Trade Commission Room H-159 600 Pennsylvania Ave., N.W. Washington, DC 20580 Re: Sliding Scale 2005, Project No. P054503 Dear Secretary: I am writing in response to your invitation to comment on the Commission's proposed amendment to the Children's Online Privacy Protection Act (COPPA) Rule. The proposal involves making permanent the sliding scale approach which would allow website operators and online services to obtain verifiable parental consent for the collection of personal information from children for internal use through sending an e-mail message to parents with additional follow up steps. I strongly support making the current sliding scale approach permanent. The sliding scale approach was initially used for the short term in hopes that parental consent technology would become widely available and be cost effective. Digital Signature technology is available primarily by companies offering it to Web site operators. It is important to note the sliding scale has worked since its implementation in 2000. Looking at the policy goals of COPPA, the sliding scale approach meets the Rule's objective. It allows web site operators who collect children's information for internal uses to continue to use the e-mail system for parental verification. There are noted differences between the low risk internal uses of children's information to that of third parties. For these reasons, companies providing children's information to the public or third parties should have to meet the stricter requirements for verification of parental consent. If these companies are unable to invest in the software for their company, there are several companies in the safe harbor program that will ensure COPPA compliance. Lastly, the danger to children comes from web site operators or online services that disregard COPPA and make no attempt to follow the Rule. The Federal Trade Commission has successfully enforced COPPA with several violating companies opting to pay large settlements under consent decrees. It is through the Federal Trade Commission's enforcement of COPPA and the online educational assistance provided to companies that will ensure compliance with the Rule. Sincerely, Belinda Brewer