A group of 17 consumer advocacy groups are calling on the FTC to issue new rules that will strengthen COPPA privacy protections for underage Internet users. The advocacy groups filing with the FTC include The Center for Digital Democracy, Campaign For a Commercial-Free Childhood, Center for Science in the Public Interest, Children Now, Consumer Action, Consumer Watchdog, Consumers Union, National Consumers League, and World Privacy Forum.
The advocacy groups argue that stronger protections for child users are necessary to protect children from aggressive advertisers who increasingly attempt to contact kids through online games, mobile services, and virtual worlds. COPPA was signed into law in 1998 and implemented by the FTC beginning in 2000, so the advocacy groups think that many of COPPA's provisions are now out of date and of questionable efficacy.
The advocacy groups want the FTC to develop COPPA guidelines covering minors over 13 years of age, extend COPPA guidelines to all digital platforms that target underage users, update its definition of personal information to include new concepts like IP address and geolocation, close loopholes that allow business to contact children without parental consent, and require major business to report their data collection practices to the FTC.
The report also wants the use of data transmitted from a child's cell phone to be closely monitored. The report argues that data generated by phones equipped with GPS sensors can easily be used to determine a child's specific real-world location. Location can also be used to let advertisers contact children without parental consent, by having a child's location trigger automatic text messages or pop-ups containing advertisements.
On June 30th, a number of organizations legitimately concerned about on-line child privacy and predatory child marketing submitted a brief to the Federal Trade Commission requesting an upgrade and extension of existing COPPA (Child Online Privacy Protection Act) regulations to protect children. Whyville.net was specifically called out in that report as a site that “emphasizes its ability to reach children between eight and fifteen years old and offers 'market research' based on their audience”. This claim regarding Whyville appears to be based solely on a single online document that describes very generally the services we offer to potential sponsors.
Numedeon, Inc. the creators of Whyville would like to clarify that. by corporate policy, we do not provide to any sponsor information that could be used to identify, contact, or target individuals. Examples of research projects in Whyville include surveys that evaluate children's knowledge and awareness of coral reef ecology ( "Which of the following has a positive human impact on a coral reef? ") and children's opinion on school vending machines ( "Do you think the vending machines at school offer healthy food choices? " ). Our market research projects are not subversive sales campaigns; they give children a voice on issues that impact their lives and their world.
Whyville is a site built around learning and education. The site has a worldwide reputation for protecting the safety and privacy of its virtual citizens. Whyville has won many awards for its efforts, and its sponsors represent a wide range of public and private organizations, many of whom are also recognized internationally for their efforts to educate, inform, and protect children.
Numedeon commends the authors on their intent, and we support strong protections for children. Indeed, safeguards for children must evolve at pace with this ever changing and ever more sophisticated world of digital monitoring. We welcome the opportunity to work with other organizations and the FCC in developing policies and procedures to further protect children. Numedeon stands firmly on the side of protecting and empowering children, and our actions affirm this policy.
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