Re: Proposed IETF Statement Concerning Personal Data for Review

["John R Levine" <[e-mail]>]

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

Really, no.

Keep in mind that COPPA is only concerned with PII, so the only thing it 
would affect is whether 12 year olds can join mailing lists and create 
datatracker accounts.  We do not know or care who is looking at the web 
sites and mail archives.

If you say you allow under-13's to sign up at all, COPPA deliberately 
requires all sorts of record keeping that in practice means we'd have to 
hire one of a handful of specialist COPPA compliance firms.  It is not 
adequate to say we asked her mother who said it's OK.

Just leave the boilerplate alone.  It avoids significant legal exposure, 
and in practice limits nothing.

R's,
John

> 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.