[Web4lib] RE: COPPA and UGC in the library

[Peterson, Glenn]

Re: publicly-supported libraries and COPPA, according to the FTC
website:

"The Rule applies to operators of commercial websites and online
services directed to children under 13 that collect..."

http://www.ftc.gov/privacy/coppafaqs.shtm

There are also exceptions that may cover LT depending on the information
solicited from kids.

----------------------------------------------------------------- 
Glenn Peterson           gpeterson at hclib.org 
Web Administrator        http://www.hclib.org 
Hennepin County Library  voice: 952-847-8659 
12601 Ridgedale Drive    fax: 952-847-8642 
Minnetonka, MN 55305 
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Message: 9
Date: Tue, 6 May 2008 21:32:26 -0400
From: "Tim Spalding" <tim at librarything.com>
Subject: [Web4lib] COPPA and UGC in the library
To: web4lib <web4lib at webjunction.org>
Message-ID:
	<63d3c8ce0805061832o3843d41dq902a716f5fd09fd0 at mail.gmail.com>
Content-Type: text/plain; charset=WINDOWS-1252

We're working on a feature that will provide reader reviews in the
OPAC, and allow library patrons to contribute reviews.

We're looking at the implications of the Children's Online Privacy
Protection Act (COPPA). It seems clear to us that collecting reviews
from children under 13-not to mention emails for
account-resets-violates COPPA, unless we go through onerous
parental-notification and approval processes. If a 12 year-old users
their review to talk about their hobbies, mention where they go to
school or-worst case-give their name, we're in violation. We are, of
course, going to allow libraries to moderate reviews before they go
live, but COPPA is not just about display. Merely *collecting* the
information triggers the law. We aren't lawyers, of course, but it
seems clear to us we can't do it.

*BUT* we seem alone in this concern. Of the various libraries and
commercial products that allow user-contributed content in the
catalog, we haven't found any that address this issue.

Does anyone know what's going on here? The OPACs that allow tagging
and reviewing-do any prohibit under-13s?

Tim

-- 
Check out my library at http://www.librarything.com/profile/timspalding




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End of Web4lib Digest, Vol 38, Issue 6
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