In December, CDD urged the FTC to reject the verifiable parental consent mechanism for COPPA (Children's Online Privacy Protect Act) proposed by AgeCheq.  The comments are attached.  Ensuring meaningful parental consent so their child's data can be gathered and used requires a robust and effective system.  Parents need to understand precisely what data is collected and by what means; how it is to be used--now and in the future--as well as the business models and online marketing practices that can affect them.  CDD and its attorneys at Georgetown Law Center found a range of problems with Ag

 Consumer, Children’s, and Privacy Groups Challenge Federal Trade Commission’s Proposed Settlement

with TRUSTe (True Ultimate Standards Everywhere, Inc.) As Too Lenient

Stronger Sanctions Needed for TRUSTe’s Violation of the Public Trust

 Consumers—Especially Parents—Materially Harmed by Years of Deception

Last summer, we asked the FTC to provide us with information on the so-called "Safe Harbors" for the Children's Online Privacy Protection Act (COPPA).  We told the FTC that the public needs to review how these Safe Harbor programs actually operate including how they ensure that a child's privacy is protected.  The FTC has not made the information available, claiming that if it provided it the companies under its purview would be less forthcoming to the agency.  That position is absurd and inappropriate.  When we are talking about programs that are supposed to protect the privacy of children