Submission Number: 00082
Received: 12/14/2011 2:54:17 PM
Agency: Federal Trade Commission
Initiative: 16 CFR Part 312; Children’s Online Privacy Protection Rule Review; Project No. P104503
Attachments: No Attachments
I am concerned that the COPPA Rule, which is supposed to create a safer online experience for children, has not been updated in over ten years. During that time, the online environment has changed dramatically and children spend more and more time online.
Internet advertisers use behavioral targeting and one-to-one marketing strategies on children without parental consent. The loopholes in the current version of the COPPA Rule make it easier for advertisers to do this. Parents would like to supervise what their children are doing online, but find it difficult to do so because privacy and advertising policy notices are hard to find and impossible to understand.
Advertisers and other website operators use increasingly sophisticated technologies to identify individuals. The COPPA Rule should be updated to reflect the reality that “personally identifiable information” about children is an expanding category. In particular, the COPPA Rule should clarify that operators must ask parents’ permission before they collect:
Children’s IP addresses
Children’s geolocation information
Children’s screen and user names
Photographs and videos of children
I urge the FTC to update the COPPA Rule without delay to ensure that COPPA remains an effective tool for protecting children and assisting parents.