To the Commissioners:
We are writing in response to the FTC’s request for comments about the COPPA Rule.
We are troubled that industry is lobbying the FTC to weaken the rules and carve out exceptions. Children need more protection, not less. Many children now spend more than half of their waking hours on digital devices. Much of that time is spent on platforms whose business model consists of extracting as much sensitive data as possible in order to serve powerful, manipulative “behavioral” advertising tailored to the child’s interests.
Congress passed COPPA to protect children, not to promote business interests. It is the only federal law that protects children from exploitative data collection and harmful digital marketing. Parents rely on COPPA to keep their children safe, keep corporate surveillance at bay, and curtail how companies use and share children’s personal information.
Any changes the Commission makes to the COPPA Rule should be to strengthen privacy protections for children, rather than making it easier for tech companies to exploit them.
There is only one federal law to protect children’s privacy online: the Children’s Online Privacy Protection Act. COPPA empowers parents to protect their children’s privacy, puts important restrictions on what data can be collected from children, and limits how kids’ data can be used. In September, acting on a complaint filed by CCFC, the Federal Trade Commission levied a record-breaking fine on Google for violating COPPA, and forced them to make significant changes to YouTube’s data collection and marketing practices.
Now, Google and other industry players want to weaken COPPA, so that they can keep collecting kids’ sensitive data for manipulative personalized marketing. And unfortunately, the FTC seems to be bowing to the pressure – they’ve called for an early review of COPPA’s effectiveness, years before such a review was required by law. One commissioner even described the review as “taking care of children and data both,” as though extracting marketing data is just as important as protecting kids!
CCFC is leading the charge to not only save COPPA, but strengthen it. On October 7, we participated in the FTC’s Future of the COPPA Rule workshop and told the FTC directly to stand up for kids. And along with our allies at the Center for Digital Democracy and the Institute for Public Representation at Georgetown Law, we’ll be filing extensive comments with the FTC, explaining why the tech industry’s desire to “innovate” – that is, to make more money – does not outweigh kids’ right to privacy.
Now, the FTC needs to hear from you. Comments – including this one – are due by December 9, 2019. Big tech companies are already mobilizing their lobbyists and allies to call for the end of COPPA. Please sign and tell the FTC to stop protecting tech profits and put kids’ wellbeing first!