Submission Number: 00028
Received: 10/30/2011 8:24:15 AM
Agency: Federal Trade Commission
Initiative: 16 CFR Part 312; Children’s Online Privacy Protection Rule Review; Project No. P104503
Attachments: No Attachments
Topic: Does the combination of date of birth, gender, and ZIP code
provide sufficient information to permit the contacting of a specific
individual such that this combination of identifiers should be included
as an item of personal information?
My opinion: No, more information other than date of birth, gender, and ZIP code is needed to permit the contacting of a specific individual and be considered an item of personal information.
Argument for the opinion:
Added information such as screen names, parental consents, and device identification can help with the enforcement of the Children’s Online Privacy Protection Rule. The current rule is outdated, dating back to 2005. With the advancement in technology, such as our wireless, portable devices, children under the age of 13 have easier access to the internet today. Working in a retail field, children between the ages of 5 and 13 are continuously requesting parents to purchase these portable wireless devices, as gifts for holidays or special occasions. Adding extra measures to help protect the child privacy is certain especially when these devices become of affordable costs to the average society.