The Wall Street Journal reported late last night that Facebook is working on a plan to enable children under 13 to use its service, a way of being compliant with the law that my wife and I helped pass back in 1998 (COPPA). Working with a coalition of child advocacy, public health, consumer and privacy groups, we are also behind the FTC's current COPPA review designed to strengthen its implementation for the mobile and social marketing era.
I just emailed the FTC urging them to look very carefully at any Facebook proposal to target children. A whole new set of safeguards to regulate the kind of viral and manipulative marketing already found on Facebook--including when it targets teens-- would have to be crafted. Rules to limit data collection about children and their friends would also have to be enacted. Parents would have to be told how Facebook and its advertisers really mine and uses data, for permission to be meaningful.
Facebook has to offer safeguards for its entire platform--include mobile, gaming, and for its third party and marketing partners. It can't encourage a child to trigger data collection from their friends and schoolmates--so privacy rules have to address the so-called social graf. Facebook is already targeting teens with junk food campaigns that threaten their public health. It must enact a new code of conduct that ensures young people are treated responsibly on the platform. For younger children--the service should be commercial and marketing-free. How Facebook address child privacy will be a litmus test of whether it will engage responsibily now that it's a publicly traded company.