Let's hope the Federal Trade Commission has a sense of humor. On the eve of the agency's release of updates to the Childrens Online Privacy Protection Act, the Interactive Advertising Bureau has come up with a cartoon and a message in a blog post: Don't be a Grinch, FTC.
Coppa is the law that protects childrens' privacy by requiring websites to obtain parental permission before collecting kids' personally identifiable information, like email addresses. Updates to the 1998 law could be released next week, FTC chairman Jon Leibowitz said yesterday during a Congressional Privacy Caucus briefing.
But certain provisions of the proposed updates may go too far, the IAB argues, destroying the Internet experience for its youngest users. Thus, the cartoon shows Santa Claus taking a sledge hammer to a tablet, while devastated children look at broken mobile devices.
"We thought about doing an op ed or a case study, but we wanted to take this subject matter from a different angle. We tried to find a way that doesn't stick a finger in the FTC's eye too deeply," said Mike Zaneis, the IAB's svp and general counsel.
Some of the changes proposed could limit ad-supported apps and websites, the IAB argued in its comments to the FTC.
For example, the FTC is considering expanding the definition of personal information to include clickstream data and persistent identifiers. The agency is also considering extending a website's liability for marketing to the activities of its partners. New rules could also hold websites accountable under the law even if they don't target children, but have attracted kids.
"These changes don't protect kids," Zaneis said. "If you put this strict liability on the publisher, and they can't do business with analytics companies, they won't have ads. There will be fewer kids offerings; you'll be talking about walled gardens for everything kids use from research to games. Disney will be all right, but the little guys won't."
Predictably, the IAB's cartoon got a rise out of leading privacy advocate Jeff Chester, who called the cartoon a "desperate attack" in a dueling blog post on the Center for Digital Democracy's website. "It shows the IAB does not have a sense of social responsibility, let alone an ability to be honest about what their members do with their help that expands data collection, promotes surveillance and manipulates the public."