[Systems] SL Social Help and COPPA

Bernie Innocenti bernie at codewiz.org
Sat Jun 6 16:58:55 EDT 2015

On 05/31/2015 05:56 AM, Sam P. wrote:
> Hi,
> I was thinking a little more about the social help web service.  It is
> probably going to get a few sign ups from people under the age of 13
> years old (sugar's target market, right?).  It is also hosted on a
> server in the USA.  Therefore I think that means we need to make it
> comply with the COPPA [1].
> I'm completely at a loss of how to comply.  It appears that email
> addresses are classes as PII (personally identifying info), so require
> parental consent to be gather.  Discourse (the forum) software is
> practically inseparable from email addresses.  Requiring parental
> consent would wreck the whole social help experience (being able to
> quickly ask a question).
> Any ideas?

My understanding of COPPA is that you only need to comply "if you
operate a commercial Web site or an online service DIRECTED TO CHILDREN
UNDER 13 that collects personal information from children or if you
operate a general audience Web site AND YOU HAVE ACTUAL KNOWLEDGE that
you are collecting personal information from children". (emphasis mine).

So you should be fine if your service is not explicitly directed to
children or you have no actual knowledge that your users are children.
IANAL, but the fact that most websites in the US let me create an
account without checking my age suggests that this is how COPPA is being
interpreted by most site operators.

> Thanks,
> Sam
> [1]  http://coppa.org/
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 _ // Bernie Innocenti
 \X/  http://codewiz.org

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