I-Safe denied COPPA Safe Harbor - look at what is said!
- 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
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
Nancy Willard, M.S., J.D.
Center for Safe and Responsible Internet Use