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I-Safe denied COPPA Safe Harbor - look at what is said!

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  • Nancy Willard
    Hi all, Most of you know that I have grave concerns about the Internet safety curriculum provided by I-Safe - primarily because they present inccurate
    Message 1 of 1 , Jun 8, 2010
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      Hi all,

      Most of you know that I have grave concerns about the Internet safety
      curriculum provided by I-Safe - primarily because they present inccurate
      information in a fear-based manner. Here is an old blog:

      I-Safe had recently applied to be an organization that provides Safe
      Harbor status to web sites under COPPA. I had concerns about this
      because over the last decade I-Safe has had several relationships with
      companies that engage in digital identification.

      While I do not know this to be a fact, I was concerned that I-Safe was
      going to use this Safe Harbor approach to set up relationships with
      sites and then go to schools and suggest they help digitally identify
      students - which would then allow the sites and the digital
      identification company to better profile the children for advertising.
      Let me be very clear. I do not know that this was their plan - but based
      on past activities I was afraid this was their plan.

      BUT their application was denied.

      But very significantly was the third reason it was denied. This is from
      the FTC letter:


      Further, although i-SAFE may not be legally required to comply with
      COPPA because of
      its non-profit status, the Commission is concerned that i-SAFE’s own
      website does not provide
      protections for children equal to or greater than the Rule. As several
      commenters pointed out, i-
      SAFE’s website does not comply with COPPA in several respects. i-SAFE
      collects an extensive
      amount of personal information from children during its i-Mentor
      registration process, without
      first notifying parents and obtaining parental consent, in direct
      contrast to COPPA’s
      requirements.6 In addition, i-SAFE’s privacy policy misstates its
      information collection
      practices with regard to children under 13. The policy states that
      “[w]hen a child or young adult
      under the age of 13 attempts to register with i-SAFE, we ask them to
      obtain their parent’s
      consent.” According to the Commission’s review, i-SAFE does not instruct
      children to obtain
      their parent’s consent or provide a mechanism for parental consent.

      The Commission feels strongly that any organization – including a non-profit
      organization – to which it grants safe harbor status should itself
      comply with COPPA when
      interacting with children online. In the case of i-SAFE, which promotes
      itself as a leader in
      educating children on Internet safety, the failure to provide COPPA
      protections is particularly
      troubling. This failure also would undermine i-SAFE’s authority to
      enforce other website
      operators’ compliance with COPPA.

      I strongly encourage you to look elsewhere for your Internet safety
      education materials.


      Nancy Willard, M.S., J.D.
      Center for Safe and Responsible Internet Use
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