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The Future of Online Services for Kids

Yesterday we filed comments on the Federal Trade Commission’s (FTC) proposed changes to the Children’s Online Privacy Protection Act (COPPA).  Our comments advises the FTC about changes that could discourage the development of online services for kids.

So what is COPPA?  Well, COPPA regulates the online collection and use of information about a child (a child is anyone under 13).  While a noble goal, COPPA has unfortunately discouraged many services from developing appropriate content for kids.

That’s because COPPA exposes any online service for those under thirteen to potential legal liability.  As a result, many services forbid those under 13 from using their services. For example, YouTube forbids those under 13 from using its service.  Likewise, Pandora music service is only available to those over 13.

This past September, the FTC proposed changes to COPPA, expanding its scope and legal liability.  When we heard about the changes we worried about the effects.  CCOPPA current rules already discourage most online services from serving those under 13, so what will happen if the rules get tougher and the liability greater?  How many more sites will just avoid serving kids?

To ensure that kids have access to online services, our comments suggest ways the FTC could modify its proposal to keep online services that benefit kids, their parents, and teachers.

A few things we asked the FTC:

  1. Don’t  treat a family photograph alone as “personal information”
  2. Treating a “Like” or “Tweet” button as “collection” of personal information is not viable in a socialy-networked world
  3. The FTC should not eliminate existing methods of parental consent, especially if that would cause the collection of even more personal information.
We hope the FTC considers our suggestions.   More kids are going online every day and in many ways, so we ought to be encouraging more online services to create appropriate content for kids.