Industry-funded Group Future of Privacy Forum vs. Kids Online Privacy [Annals of COPPA]

First, the Future of Privacy Forum should do better and embrace a more truthful standard when it files documents at federa agencies.  In its COPPA filing, the group claims it is a "think tank."  No where do they mention they are funded by the largest data collection and targeting companies, including Facebook, Google, Yahoo, Microsoft, AT&T, etc.  The group's financial conflicts of interest on data privacy issues should be addressed upfront in any proceeding or public communication. 
 
But the group's analysis is flawed, skewed to serve the interests of its funders.  It's orientation is narrowly focused on business practices, versus the need to protect consumers, citizens and in this case children under 13.  They fail to provide the FTC with a more accurate analysis of how digital marketing works online, and the responsibility sites have to ensure their data practices protect children.  The Forum invokes the "digital sky will fall" tactic by claiming that including persistent identifiers as personal informaton will "bring to a halt the basic informaton relied on by advertisers..."  It's very revealing that the Forum appears less interested in supporting greater privacy rights for invididuals, versus helping the very companies that fund it continue to do data collection practices as usual.  Take for example the Forum's fallacious claim that children's sites and apps will be "at risk of being impaired by the proposed regulations that would impede advertising and analytics."  How does parental control to decide what can be done regarding the privacy of their child or children threaten to undermine the "valuable educational and entertainment resources" of online kids content?  This is nonsense and an insult to parents and those who care about their privacy and welfare.
The Forum is also working on mobile marketing issues, so it's not suprising it doesn't support what children's privacy advocates have called on the FTC to do: regulate the use of geo-location data.  They offer a fairly tale view of how marketers would use a kids geo-location data ("to help children determine where they are or how to find nearby resources").  They should ask their funders to tell them how young people are targeted today via geo-location--it isn't about helping them find home!  The Forum also tries to protect mobile app developers, getting them off the hook to ensure that kids privacy is respected. 
One would hope that the Forum could do better in providing truly objective and more-indepth information to federal regulators.  If is ever to be more than a digital Rodney Dangerfield type group that fails to have the respect of its peers, it will need to become more intellectually and politically independent.