Barbara,
COPPA went into affect last year. Prior to its becoming effective, we
consulted with our attorney who specializes in "electronic issues". We
issue the following guidance to our webmasters and listmasters.
Dave Simon
Sierra Club
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Children's Online Privacy Protection Act (COPPA) Compliance
The Children's Online Privacy Protection Act of 1998 and the FTC's
implementing regulations (collectively, "COPPA") took effect on April 21,
2000. COPPA is intended to protect the privacy of children under the age of
13, primarily in their activities on sites (websites, lists, chats, etc)
that are targeted at children. If an operator of any site learns that a
user is under 13, the operator must obtain parental permission before
collecting or disclosing any personal information about the child. Without
permission, an operator must remove all personal information (name,
address, phone, email address) about the child from the site and the
operator's archives. Only sites (or portions of sites) which are targeted
at children are automatically governed by COPPA. With respect to other
"general audience" sites, COPPA is invoked only if the operators have
actual knowledge that the site is collecting or disclosing personal
information from a child.
Impact on Club Websites
Where our website has content contributed by children under 13 or has
forms, guestbooks, or other functions in which children could identify
themselves and provide personal information, the entity webmaster must
obtain, concurrent with a child's participation, a letter of parental
permission or the child's personal information must be promptly deleted.
The parental permission letter should say specifically, "My child, ______,
has my permission to participate on Sierra Club web sites." This permission
must be forwarded to the Sierra Club (attention Webmaster, 85 Second St,
2nd Floor, San Francisco, CA 94105)."
Impact on Club Email Lists
If a list participant identifies his/herself as a child under 13, please
notify [log in to unmask] The listmaster will attempt to obtain
parental permission so that the child can continue to participate in the
email list. In the meantime, the child will be removed from the email list.
The listmaster will also send the following message to the child:
"Thank you for your interest in the Sierra Club and our efforts to protect
the environment. Due to the Children's Online Privacy Protection Act of
1998, your continued participation on the email list to which you were
subscribed requires the permission of your parents. This letter should say
specifically, "My child, ______, has my permission to participate on Sierra
Club websites and email lists." Please have your parents send the letter to
the Sierra Club (attention Email Lists, 85 Second St, 2nd Floor, San
Francisco, CA 94105). When we receive and confirm your parent's permission
letter, we will add you back to the email list."
If it turns out that the additional workload of verifying parental
permission is significant, this policy may be revised.
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