ARLINGTON, VIRGINIA – The American Consumer Institute (ACI), a leading nonprofit 501(c)(3) education and research organization, has officially submitted its comments to the Federal Trade Commission (FTC) regarding the proposed updates to the Children’s Online Privacy Protection Rule (COPPA). With a steadfast commitment to protecting consumer interests, ACI aims to address critical concerns surrounding the feasibility of obtaining verified parental consent through facial recognition technology and the proposed criteria for determining age-appropriate websites.

Read the full comment here.

Key Points:

  • Critical Evaluation of COPPA Updates: ACI has raised significant concerns about the practicality and privacy implications of the FTC’s proposed methods for verifying parental consent, especially facial recognition technology.
  • Advocating for Clearer Definitions: The submission highlights the need for more precise definitions in determining whether a website is targeted at children, arguing against including vague factors that could unfairly burden website operators.
  • Privacy and Security Risks: ACI points out the substantial privacy and security risks associated with collecting more personal information than necessary, especially with methods that could inadvertently collect sensitive demographic data.
  • Operational and Financial Burdens: The proposed rule changes could impose considerable operational and financial burdens on companies, especially small businesses, due to the required manual verification process by trained professionals.
  • Recommendations for Revision: ACI suggests revising the rule to clarify age-appropriateness criteria and reconsider the need for parental permission through photos to ensure consumer safety while maintaining a predictable regulatory environment for businesses.

The American Consumer Institute underscores the importance of updating COPPA to reflect the evolving digital landscape. However, the Institute cautions against implementing measures that could inadvertently compromise privacy, discriminate against specific users, or place unsustainable burdens on businesses. ACI advocates for a balanced approach that prioritizes protecting children’s online privacy while fostering a healthy digital ecosystem conducive to growth and innovation.

“Remaining compliant with the rules would prove costly as it would require companies to hire many new workers or divert resources. Small businesses would struggle to keep up, as they may not have the time or resources to comply with these regulations,” said ACI Policy Analyst Trey Price. “Clarifying the rule on whether a website is age-appropriate as well as reconsidering the provision on parental permission through photos would go a long way toward guaranteeing consumer safety.”

ACI remains committed to engaging with policymakers, industry stakeholders, and consumer advocates to foster a regulatory environment that protects consumers and supports technological advancement.

For further details on ACI’s stance on SB 968 and other consumer advocacy efforts, please contact [email protected].

The American Consumer Institute is a nonprofit education and research organization. For more information about the Institute, visit www.TheAmericanConsumer.Org or follow us on X @ConsumerPal.