| Comment Number: | 546345-00012 |
| Received: | 3/1/2010 12:00:00 AM |
| Organization: | Center for Digital Democracy |
| Commenter: | Jeffrey Chester |
| State: | |
| Agency: | Federal Trade Commission |
| Rule: | i-SAFE, Inc. Application for Safe Harbor |
| Attachments: | 546345-00012.pdf Download Adobe Reader |
Comments:
-The FTC should not approve I-Safe's application unless I-Safe amends the application to provide greater protections for children's privacy online. -I-Safe's Guidelines allow participating Web sites to collect personal information about children without placing a privacy notice in the locations where they collect such information. The COPPA Rule requires that Web site operators place a link to their privacy policies at all locations where they collect personal information. I-Safe only requires that Web site operators place a link to their privacy policies where they collect online contact information. This allows operators to collect sensitive information such as phone numbers and physical addresses without reminding children and parents about their privacy policy. -I-Safe's Guidelines discourage parents from raising awareness about problems with the data collection practices of I-Safe licensees. I-Safe only permits a parent to complain after she or her child has provided personal contact information to the Web site operator. Participants in I-Safe's complaint resolution process must agree to keep all aspects of the complaint resolution process confidential. This suggests that complainants may not be able to discuss their experiences with consumer groups, attorneys, the FTC, or even Congress.