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No Consent Mechanism Is Perfect I explained to the FTC during the COPPA rule hearings a story about how when my son was a senior in high school, the school had rejected a note I had signed excusing his absence, never having seen my real signature before (instead having become very familiar with his forged version of my signature). The verifiable parental consent mechanism has to be designed to ensure the likelihood that a parent is involved. Credit & debit card verification, toll-free telephone numbers where the parent must call, faxes, snail mail consent forms & digital signature mechanisms have all been accepted as reasonable means of VPC. Certain other forms of centralized consent mechanisms have been recently launched or are about to be launched. WiredKids will house a Central Site Registry, designed to help collect donations for its nonprofit programs while allowing sites to join the group & have WiredKids collect the requisite consent, at the same time it is collecting donations from parents for its programs which support equitable access, educational use of the Internet & safety for children. The web sites must be certified as COPPA-compliant & submit themselves to WiredKids audit oversight in order to be eligible to take part in the central registry. They must also pay a sliding scale entrance fee, that helps support the WiredKids projects. There is (for a limited two year period) a sunset provision permitting online consent for certain internal information collection uses. It cant be used if any interactivity is involved, such as chat, etc., which requires the use of verifiable parental consent. Sites must also notify parents if their children (under thirteen) have provided the site with their e-mail address to either register at the site, or receive a newsletter or be put on some kind of online mailing list. |