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

For months, CDD has been in contact with the Federal Trade Commission over the actual efficacy of the so-called "Safe Harbors" programs established to address children's privacy thru the Children's Online Privacy Protection Act (COPPA).  We have major concerns about how these programs are structured, and whether they meaningfully ensure privacy of young people.  We have asked, via FOIA, for a detailed documentation on how the COPPA Safe Harbors operate.  The FTC has not--to date--provided the information parents and the public require.  CDD will ensure, however, that there is meaningful acc

[excerpt from attached letter]

Dear Chairwoman Ramirez: