If you care about children’s online privacy, the Federal Trade Commission needs to hear from you.
The FTC has proposed important changes to the implementation of the Children’s Online Privacy Protection Rule (COPPA Rule), adopted in 2000 to create a safer online experience for children. But the online environment for children has changed dramatically over the past ten years, while the COPPA Rule has never been updated. The FTC’s proposed changes would provide important safeguards protecting children from the technologies and techniques that advertisers use to identify, track, and target kids online and on mobile devices.
Please follow the steps below to submit a comment to the FTC.
- Click here to open the FTC’s COPPA comment page (the page will open in a new window so you can still access these instructions).
- Fill in the identification fields. Please do not enter “CCFC” in the organization field, as we will be filing our own official comments. Please note: all comments to the FTC are public and will be posted on the FTC website. The FTC will not, however, post your street address.
- Write your comment in the box marked “Comments.” We encourage you to use your own words, but if you prefer, you can cut and paste the sample comment below. If you are a parent and/or work with children, you may wish to include that information as well (e.g., "As a parent, I am would like to supervise what my children are doing online…” or "As an educator, I am keenly aware of how much time my students spend online…”)
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.