Today, the Marketing Research Association (MRA) filed comments with the Federal Trade Commission (FTC) on their proposed amendments to the Children's Online Privacy Protection Act (COPPA) rules. COPPA gives parents control over what personal information websites may collect from children under the age of 13. MRA, the leading and largest nonprofit association of the survey and opinion research profession in the United States, expressed concerns with the FTC's proposals to remove the "email plus" option of verifying parental consent, requiring that researchers vouch for the data security standards of their research partners, and minimizing and data that they collect and maintain.
MRA’s biggest concern before the release of the proposed amendments was the age threshold, a key target of many activists. The Commission thankfully did not propose raising the age threshold from under 13 to under 18. COPPA requirements would be less effective for minors 13 or older – in fact, enforcement would likely have been either overboard or impossible. It would likely have required age verification of every single Internet user in order to verify the true identity of every user. Moreover, the constitutional concerns about free speech rights remain the same as they did when COPPA was first written.
MRA's concerns with the proposed amendments include:
- the elimination of the "email plus" method for verifying parental consent is a misguided attempt to spur innovation by eliminating the most effective and affordable means available;
- requiring that researchers take "reasonable measures" to ensure that their research partners maintain reasonable data security procedures is not a standard that could be easily met and may encourage the eventual adoption of a regime whereby federal entities audit and micromanage the data security practices of all researchers; and
- limitations on the amount and type of information that researchers can collect and maintain could lead to micromanagement of the research process by government entities lacking familiarity with the processes and practices of all businesses that would be impacted by their implementation, including the many processes and practices of survey and opinion research.
MRA looks forward to continued dialogue with the FTC and the continued pursuit of our common goals: the protection of children and respect for their parents.