Implementation of the Children’s Online Privacy Protection Rule
Comments of Center for Democracy & Technology (CDT), The Progress & Freedom Foundation (PFF), & Electronic Frontier Foundation (EFF)
June 30, 2010

CDT, PFF, and EFF have filed joint comments to the FCC regarding COPPA.  They state that the COPPA rule is in place to prevent information being collected from children under the age of 13.  This is something that the groups believe have been successful and that has improved parental supervision of what children are viewing online.

Currently there is consideration to expand COPPA to older minors.  The groups feel that if the rules are expanded that it will bring more websites and more individuals into the process and greatly expand the hand of regulation.  They believe that by expanding the program that more information will be shared by participant websites and users.  Thus creating a situation where the program designed to protect privacy will actually increased decrease privacy.

The groups bring up four points of concern in their comments:

1. COPPA’s effects on children’s online privacy and safety
   
2. COPPA expansion raises grave privacy and constitutional concerns
   • Several approaches to expanding COPPA would impose age verification mandates on general-interest websites
   • Expanding COPPA would increase data collection, reduce user privacy, and burden speech unconstitutionally
     
3. COPPA statute is broad and does not require modification to permit the commission to regulate emerging technologies
   
4. The FTC should pursue a strategy of enhanced enforcement, increased education efforts and promotion of empowerment solutions

You can read the comments in full here.