It’s Arrived! FTC’s Proposals for COPPA amendments

FTC Seeks Comment on Proposed Revisions to Children’s Online Privacy Protection Rule Changes in Technology Drive Proposed Updates

The Federal Trade Commission is seeking public comment on proposed amendments to the Children’s Online Privacy Protection Rule, which gives parents control over what personal information websites may collect from children under 13. The FTC proposes these amendments to ensure that the Rule continues to protect children’s privacy, as mandated by Congress, as online technologies evolve. The Commission proposes modifications to the Rule in five areas: definitions, including the definitions of “personal information” and “collection,” parental notice, parental consent mechanisms, confidentiality and security of children’s personal information, and the role of self-regulatory “safe harbor” programs.

FTC Seeks Comment on Proposed Revisions to Children’s Online Privacy Protection Rule Changes in Technology Drive Proposed Updates

Wow… so, after a year of research and reflection from the COPPA round table in DC, the FTC has come forward with some proposals / amendments to the Children’s Online Privacy Protection Act.  This should be VERY interesting, considering the upcoming push for kids to participate in Social Media platforms (*cough* Hearsay… Facebook *cough).  Take a look at the link above for full run down from the FTC website. Otherwise, here’s a quick bullet list.

Proposed changes include, my notes in RED:

•  Updating the definition of “personal information” to include geolocation and persistent identifiers such as tracking cookies for behavioral advertising. (Wow. I actually think this is GREAT for all those platforms now collecting location.  Seems like a no brainer in regards to children.  As for Behavioral Advertising?  Man oh man, this should be an interesting shake-down.)
• Modifying the definition of “collection” to allow children to participate in interactive communities without parental consent. (Sites must employ reasonable measures to delete all or virtually all children’s personal information before it is made public) (I’m not sure how different this is from what is already practiced?  I will need to do a deeper dive to understand what this is in exact reference to, or what this actually affects – if anything at all).
• Streamlining/clarifying information that websites give parents prior to collecting children’s personal information (adding more information in the notifications, and not hiding in only in the Privacy Policy) (This is great in “theory” – but let’s be honest… it’s hard enough to get parents to see the BIG GREEN CLICK HERE / URL at the TOP of a welcome email, regardless of the information buried within the email.  I feel this is a “good policy” amendment more than something that will prove helpful, which is sad.)
• New Parental Verification / consent opportunities (Yay! we need new methods!):

1. Electronic scans of signed parental consent forms (The modern “fax”, lol.  No brainer here.)
2. Video-conferencing (Bwaha! Dear gawd almighty – this is BONKERS for scaling… Great for quick-fire Customer Service & Skype, nuts for staffing and sustaining large groups)
3. Government-issued IDs checked against a database (note: promptly deleted after verification) (Interesting! Lots of “Big Brother”-esque thoughts stream through my head, and I don’t necessarily think its a bad thing in regards to children… But that’s because those actions help me do my job in protecting my audience).

• PROPOSED DELETION OF EMAIL-PLUS (This is a HUGE FTC proposal. It could affect a LOT of businesses and platforms for kids. Seriously.  Not to mention, marketing emails & virtual worlds… People who have been using email plus + great policy are about to lose a LOT of numbers in registrations!  Oooo doggy!)
• New 180-day proposal for companies seeking “new” types of verification processes to be vetted and approved (or rejected) by the FTC
• Safe Harbor programs must do annual audits. (Um. Yeah. I feel like there should be biannual audits done, but in a cooperative, friendly manner.)

Overall – interesting day of information.  Commenting has started on these proposed amendments… so get on it if you feel the need to speak out.  The only yellow flag for me = deletion of Email Plus.  It has been the EASIEST method to engage kids… and the lowest barrier to entry for parents (*no comment on the easy work arounds).  I worry that this will just send kids tenfold into adult areas or into opportunities of lying to get what they want.  Overall, maybe it will be a great thing?  I think I’m just foreseeing the crunch various companies are going to have between removing the “email plus” approval system and entering the “full verification” method.  I know a lot of companies have used email plus in a positive method – with extensive filters, moderation systems/practices, and staffing.

So… what do you think?