How the COPPA, as Implemented, is Misinterpreted by the Public: A Research Perspective
7 Pages Posted: 28 Mar 2011
Date Written: April 29, 2010
Mr. Chairman, Members of the Senate Subcommittee, and Commissioners of the United States Federal Trade Commission: Thank you for focusing attention on the important issues of youth privacy and safety online. As researchers, we welcome the opportunity to provide input into these hearings regarding the Children’s Online Privacy Protection Act (COPPA). We write as individuals, but we work together as the principal investigators of the Youth and Media Policy Working Group Initiative at Harvard’s Berkman Center for Internet and Society. The goal of our working group is to explore policy issues that fall into three substantive categories that emerge from youth media practices: 1) Risky Behaviors and Online Safety; 2) Privacy, Publicity, and Reputation; and 3) Information Dissemination, Youth-Created Content and Information Quality. Our work is intended to consider how research on the intersection of youth and technology can and should be used to inform policy. We seek to translate research from those who study youth media practices into terms responsive to the children’s privacy hearings.
There is no doubt that protecting children’s privacy and safety is of utmost importance in our society. These issues are growing in importance with every passing year. We commend the authors of COPPA for being so deeply concerned about privacy and safety. As you consider the future of legislation and rule-making in this area, we urge you to consider the gap between the intentions of COPPA and how children and their parents perceive the implementation. It is this gap that we’d like to address in our submission. And it is our proposal that this Subcommittee consider how COPPA’s two P’s – of Privacy Protection – might be worked more effectively back into any revision of COPPA.
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