Therefore, the Rule sets forth a sliding scale approach to obtaining verifiable parental consent. If the website operator is collecting personal information for its internal use only, the Rule allows verifiable parental consent to be obtained through the use of an e-mail message to the parent, coupled with additional steps to provide assurances that the person providing the consent is, in fact, the parent. Such additional steps include: sending a delayed confirmatory e- mail to the parent after receiving consent or obtaining a postal address or telephone number from the parent and confirming the parent’s consent by letter or telephone call.If it were me, I would not go anywhere near COPPA. It seems like you don't have to worry about any of this if you don't actually collect any personal information (which is defined in 1302 (8) as one or more of:
In contrast, for uses of personal information that involve disclosing the information to the public or third parties, the Rule requires that website operators use more reliable methods of obtaining verifiable parental consent. These methods include: using a print-and-send form that can be faxed or mailed back to the website operator; requiring a parent to use a credit card in connection with a transaction; having a parent call a toll-free telephone number staffed by trained personnel; using a digital certificate that uses public key technology; and using e-mail accompanied by a PIN or password obtained through one of the above methods.9 As noted in the Rule’s Statement of Basis and Purpose, “the record shows that disclosures to third parties are among the most sensitive and potentially risky uses of children’s personal information.”
(A) a first and last name;Therefore, if you just have kids sign up with a username and password, and ensure that they use an alias/nick and not their real name, it looks like you're off the hook. Don't collect email address, location, telephone number, etc. This makes running a typical forum kind of hard as you can't do e.g. password recovery or email notification of posts, but it's a lot easier than having to FAX a form to everyone that signs up.
(B) a home or other physical address including street name and name of a city or town;
(C) an e-mail address;
(D) a telephone number;
(E) a Social Security number;
(F) any other identifier that the Commission determines permits the physical or online contacting of a specific individual; or
(G) information concerning the child or the parents of that child that the website collects online from the child and combines with an identifier described in this paragraph.
posted by FreezBoy at 7:18 PM on November 21, 2006