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Submitted to Federal Trade Commission
March 8, 2024
Comments in response to FTC proposed rule change

ConnectSafely is pleased to comment on the proposed changes to COPPA. We agree that it’s appropriate, from time to time, to revisit legislation to adjust for new technologies, new business models and changes to potential online threats.

Biometric data: While we support strong safeguards to assure the privacy, security and timely deletion of biometric data, we also recognize that biometric data can enhance privacy and security for users, including children. We strongly believe that biometric tools such as fingerprint and facial recognition should be available for all users to make sure that children and teens, as well as adults, are able to access services in the most secure way possible.

Directed to children: We agree that these protections should apply to apps and websites that are “directed to children,” but urge the FTC to consider and potentially mitigate the ambiguous nature of this phrase given that many websites, including those focusing on sports, can appeal to both children and adults. 

Verifiable parental consent: While we support parental notification and consent for users under 13, we urge the Commission to create a verifiable consent system that puts as little burden on parents as possible. It needs to be very easy to use and presented in as many languages as possible. There also needs to be a simple way for the child to request their parents’ consent. 

Limits on nudging kids to stay online: While we support efforts to prevent websites from pressuring or manipulating children to spend more time online, this appears to be outside the scope of COPPA, which was designed to protect children’s data privacy.  Also, there are occasions where contact from the company may be appropriate even for young users, such as letting them know that a friend or relative wants to chat with them or has posted a picture or update or to inform children of an important safety or security update or a new feature they might enjoy using. 

Targeted advertising: While we support efforts to prevent sites and apps from tracking the behavior of children, we also recognize that children have different needs than adults. Any efforts to avoid targeted advertising should not prohibit site and app operators and advertisers from obtaining the non-personally identifiable information they need to assure that any offers or information they send is age-appropriate for the intended audience. 

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