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Re: Proposed IETF Statement Concerning Personal Data for Review

2017-02-28 02:01:25


On 28/02/17 07:45, John Levine wrote:
In article 
<CAA-e5Q0EZ6TExiJz+U0oicpst5iVteCq4JUWXNSQHVA24kOgcA(_at_)mail(_dot_)gmail(_dot_)com>
 
you write:
I think we can just say "children under 13 must obtain consent
from their parents or legal guardians". We should be fine in terms
of COPPA if parents agree with the release of personal
information.

We have no process to obtain, verify, or record parental consent. 
Unless someone anticipates an influx of middle school kids to the 
IETF, please leave the language alone.

Note that children can read IETF stuff all they want -- they just 
can't send messages in.

Let me try once more. The change I suggest to the IAOC IS:

OLD:

Our websites are not intended for use by children under 13 years old.
We do not knowingly collect personally identifiable information from, or
target our websites to, children under the age of 13.  In accordance
with the United States Children’s Online Privacy Protection Act of 1998,
if we discover that a child under 13 has provided us with personally
identifiable information, without the consent and participation of a
parent or guardian, we will remove it from our systems.

NEW:

Our websites are not aimed at children under 13 years old.
We do not knowingly collect personally identifiable information from, or
target our websites to, children under the age of 13.  In accordance
with the United States Children’s Online Privacy Protection Act of 1998,
if we discover that a child under 13 has provided us with personally
identifiable information, without the consent and participation of a
parent or guardian, we will remove it from our systems.

My reason is that we do in fact intend that our public content
could be used by anyone capable of understanding that content,
independent of age. We just don't specifically include or
exclude or aim to deal with 12 year olds, nor Irish people, nor
any other category.

Perhaps there's a better phrase than "aimed at" but "intended
for" is wrong as I read it. (To save you some time, there's only
that one change in the OLD/NEW above.)

Cheers,
S


R's, John



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