[Systems] SL Social Help and COPPA

Bernie Innocenti bernie at codewiz.org
Mon Jun 15 18:54:04 EDT 2015


The SFC might do (or they might be better than us at playing amateur
attorney).

Let's bring it up with the SL board.

On 06/15/2015 11:37 AM, Sam P. wrote:
> We have lawyers???
> 
> 
> On Mon, 15 Jun 2015 12:00 am Luke Faraone <luke at faraone.cc> wrote:
> 
>     I think these are not issues that are productive to bring up on this
>     list. If you have concerns about SugarLabs legal compliance, we should
>     discuss them with our lawyers, rather than attempting to play amateur
>     attorney here.
> 
>     On 14 June 2015 at 22:18, Sam P. <sam.parkinson3 at gmail.com
>     <mailto:sam.parkinson3 at gmail.com>> wrote:
>     > Hi Bernie,
>     >
>     > Sorry for the late reply.
>     >
>     > I'm not sure what your opinion is on this, but I would think that
>     Social
>     > Help is "DIRECTED TO CHILDREN UNDER 13" considering we link to it
>     within
>     > Sugar 0.106.
>     >
>     > I actually just mocked up something that uses the Discouse SSO api
>     to use a
>     > different auth system.  It lets users choose their name and
>     password and
>     > optionally give us their email.  That will probably fix the issue
>     either
>     > way.
>     >
>     > Thanks,
>     > Sam
>     >
>     > On Sat, Jun 6, 2015 at 1:58 PM Bernie Innocenti
>     <bernie at codewiz.org <mailto:bernie at codewiz.org>> wrote:
>     >>
>     >> 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/
>     >> >
>     >> >
>     >> > _______________________________________________
>     >> > Systems mailing list
>     >> > Systems at lists.sugarlabs.org <mailto:Systems at lists.sugarlabs.org>
>     >> > http://lists.sugarlabs.org/listinfo/systems
>     >> >
>     >>
>     >>
>     >> --
>     >>  _ // Bernie Innocenti
>     >>  \X/  http://codewiz.org
>     >
>     >
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> 
> 
> 
>     --
>     Luke Faraone;; Debian & Ubuntu Developer; Sugar Labs; MIT SIPB
>     lfaraone on irc.[freenode,oftc].net -- https://luke.wf/ohhello
>     PGP fprint: 5189 2A7D 16D0 49BB 046B  DC77 9732 5DD8 F9FD D506
> 
> 
> 
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-- 
 _ // Bernie Innocenti
 \X/  http://codewiz.org


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