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Coalition Asks FTC to Extend Child Privacy Protection to Mobile, Gaming and Other Platforms

Wendy Davis
July 1, 2010

A coalition of 17 advocacy groups and health organizations is asking the Federal Trade Commission to issue tougher regulations regarding online marketing to children.

The organizations are calling on the FTC to extend rules implementing the Children's Online Privacy Protection Act to a host of devices and platforms, including cell phones, gaming consoles, digital billboards and interactive TV. The Clinton-era law prohibits operators of Web sites and online services geared toward children from collecting personal information from minors under 13 without their parents' consent.

"When Congress passed COPPA in 1998, computers provided the only means of accessing websites and online services. Today, adults and children have many other ways to access the Internet and online services," the groups say in their comments. Organizations that have joined in the comments include The Center for Digital Democracy, American Academy of Child and Adolescent Psychiatry, American Academy of Pediatrics, Consumers Union and U.S. PIRG.

The groups also are asking the FTC to broaden the definition of personal information to include not only names and street or email addresses, but other data like IP addresses, geolocation data and other "seemingly anonymous" information that can be used for online behavioral advertising -- or serving ads to users based on data about them.

"Information collected through geolocation is especially sensitive given that it can allow for a child to be physically contacted wherever he or she is, at any time," the coalition says in its FTC filing.

In addition, the groups say the FTC should require some online sites, social networks and ad networks to file regular reports on their collection and use of visitors' data. "Unless hidden data collection practices are disclosed, the FTC cannot assess whether companies are complying with the existing rules or identify where the rules or law may need to be strengthened," the groups argue.

The FTC in March sought input about whether to revamp the COPPA regulations, last updated in 2000. Among other questions, the FTC asked whether it should expand the definition of personal information to include "persistent IP addresses, mobile geolocation information or information collected in connection with online behavioral advertising."

The National Cable & Telecommunications Association weighed in, urging the FTC not to redefine personal information. "By placing information that is associated with a particular device or computer on par with information associated with a specific person, the Commission would wholly recast the COPPA regime, requiring affirmative parental consent for many existing offerings at children's websites," the NCTA argues.

The group also said that extending COPPA's rules to emerging platforms would be premature. "With respect to nascent technologies, the Commission should give the platforms an opportunity to develop before determining whether and how specific COPPA requirements should apply," the NCTA says. "For example, there is currently no universally recognized definition of "interactive television."

The digital rights group Center for Democracy & Technology also filed comments arguing against defining IP addresses as personal information. "While it is accurate and appropriate to treat a persistent IP address as data that could be used to identify an individual (or at least a particular device), a prohibition on the mere collection of this data would undermine the very functioning of the Internet," the group said in its written comments. "Every time any user accesses a website or uses an online service -- even for the very first time -- the server that hosts the site or service receives the user's IP address."

The Center for Democracy & Technology also said the FTC shouldn't consider data collected for behavioral advertising purposes as personal information -- largely because the industry's self-regulatory standards already ban behavioral advertising to children without their parents' consent. Instead, the organization said, the FTC should "continue to monitor the uses of profile information on behalf of all users, and to consider further action should advertisers fail to live up to their commitment not to collect such information from children."

The deadline for comments, originally June 30, was recently extended to July 10.





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