Leading Consumer, Privacy, Child Advocacy & Public Health Groups Call on FTC for Stronger Children's Privacy Safeguards Under COPPA

Continuing its work to protect the privacy of children under 13 in the "Big Data" era, a coalition of leading groups just filed Comments with the Federal Trade Commission on its proposed new rules under the Children's Online Privacy Protection Act (COPPA).  Many of these groups worked to get the law passed back in 1998. Even back then the kinds of personalized data collection commonplace today was part of our design for COPPA (since the basic "one-to-one" data collection model has remained a dominant paradigm).  Under the proposed FTC rules, parents would be empowered for the first time to make decisions about whether online marketers, including on mobile devices, can stealthily use "cookies" and other unique and persistent identifiers to track and target a child.  The filing explains how companies such as Viacom (Nick.com, etc), Time Warner/Turner (Cartoon Network) and Disney (Disney XD, etc) are using advanced state of the art data collection tools to track, profile and target users online.  It discusses documents and other information we uncovered during our investigation for this filing that raise serious concerns about the commitment of many online companies to protect the privacy of kids and ensure parents are in charge.
 
Groups filing these comments with CDD include: American Academy of Child and Adolescent Psychiatry, Berkeley Media Studies Center, Campaign for a Commercial Free-Childhood, Center for Media Justice, CSPI, ChangeLab Solutions, Children Now, Consumer Action, Consumer Federation of America, Consumers Union, the advocacy and policy division of Consumer Reports, Consumer Watchdog, National Consumers League, Privacy Rights Clearinghouse, Public Citizen, Public Health Advocacy Institute and The Praxis Project.
 
The FTC filing was written by Prof. Angela Campbell and Fellow Laura Moy at the Institute for Public Representation, Georgetown Law Center.  She was assisted by her able law students.  CDD provided research and analysis.

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CDD et al COPPA.pdf373.41 KB