|July 28, 1999
Office of the Secretary
The Internet Alliance appreciates our opportunity to listen and to present our views within the Federal Trade Commission's July 20, 1999 workshop re the Children's Online Privacy Protection rule. "Verifiable parental consent" is important to build consumer confidence and trust in the marketplace. We applaud the FTC's efforts in holding these Internet workshops; we share goals in common, including consumer and policymaker confidence. We also believe that the FTC is also educating parents and other consumers about these related issues.
This is the time to allow innovative solutions to come forward, and help all of us to develop improvements in the state-of-the-art regarding "verifiable parental consent." There are serious questions that industry, inventors, and regulators need to address over time, e.g.,
Meantime, the FTC should enforce current law by prosecuting bad actors. This sends a clear signal to potential violators as well as to consumers, state, and federal policymakers. If the FTC enforces the law by dealing with the unambiguous cases, it will give the industry time to develop long-term solutions (the most efficient and the most advanced means). If the FTC picks the 'winners and losers' right now, they will short-circuit the industry's development of the best solutions.
Solutions and their technologies must be ready to use, affordable, and highly reliable. They must meet or exceed the "plug and play" threshold in the marketplace. We do not want to give parents a false sense of security through promoting less-than-effective solutions. On the other hand, we expect parents to flock to effective, usable, economic solutions -- and to choices about those attributes.
The best way right now to make rules that are effective for the long term is:
Ultimately, verifiable parental consent is about behaviors and sustained behavior change. Therefore, we should focus on usability, practicality, and acceptance by parents, children and Web sites.
The FTC should not regulate in haste, but allow the marketplace to flourish with technological advancement rather than forcing existing technology to become the standard of child protection.
Over the course of ten years, the Internet has evolved from an esoteric tool for the Department of Defense and academia to the new mass medium of the twenty-first century. Unlike any other mass medium in history, it offers an experience, which can be tailored to each user's needs and wants. It thus has the potential to become the most useful means of communication, commerce, entertainment and learning on the face of the earth. But its potential as a great leveler of opportunity, as an eradicator of the differences among people and communities in educational resources, access to capital, exposure to distant markets, and cultural opportunities can only be realized if it is allowed to continue evolving in an atmosphere of freedom, creativity and economic viability.
This revolution is moving so quickly and forcefully that we pay a price each time we are forced to retrace our steps or reverse our policies. We look forward to continuing work with the FTC to ensure that we all 'get it right.'
Jeff B. Richards, Executive Director