May 2003 -- Volume 7-- Number 4-- newsletter@truste.org
 


 
APRIL TOP 5 PRIVACY STORIES
 

1. Amazon.com Taken to Task Over Child Privacy (ZDNet UK News - April 23, 2003)

  2. A Modest Proposal to End Spam (CNET - April 28, 2003)
  3. OMB Putting Privacy Help in Place (Federal Computer Week - April 23, 2003)
  4. Spam: No Quick Victory (CNET Asia - April 28, 2003)
  5. AOL Wary of Comcast, Road Runner Mail (CNET News - April 1, 2003)

From the Desk of the Executive Director:
Amazon teaches us all lessons about COPPA.
»Learn More

Privacy Resources:
Online resources for educating yourself and your consumers about COPPA.
»Learn More

Industry Best Practices:
Ari Schwartz from the Center for Democracy and Technology describes research findings that can help you cut down on the spam you receive.
»Learn More

Stay Current:
Four privacy and security events to keep you up to date
. »Learn More

TRUSTe Tech Tip:
How to avoid common COPPA pitfalls when gathering age data.
»Learn More

Welcome New Licensees:
The newest websites to display the TRUSTe seal.
»Learn More

 


COPPA Affects Everyone -- Whether We Know It or Not
By Fran Maier

In the privacy debate, reasonable people can disagree about a lot of issues, but there is little disagreement about the need to protect children from some of the perils of online activity. In April 2000, Congress enacted the Children's Online Privacy Protection Act (COPPA). This legislation was aimed at protecting children under the age of 13 from unscrupulous use of their personal information by websites and online marketers.

COPPA is a big issue here at TRUSTe. A large percentage of websites that do not receive our certification are denied because they are not COPPA compliant. Most children-oriented sites are aware of the regulations around collecting age and other personally identifiable information. But many websites don't understand that COPPA regulations apply to their practices as well.

Recently, as you may have heard, the Federal Trade Commission (FTC) looked into the privacy practices of Amazon.com, which is not a TRUSTe licensee. The FTC found that Amazon's registration process, which collects age information, did not comply with COPPA. In its public statements, Amazon indicated that it did not think COPPA applied because it is only a "general interest site." Despite the fact that it partners with ToysRUs!

My own personal experience shows how disingenuous Amazon's claim is. For years, both of my Internet-savvy sons have come to me to help register them at children-oriented websites such as Disney.com and Nickelodeon.com. I've had to set secret codes, provide my credit card number, or even fax in permission. The boys have accepted this process and I've happily complied.

Last month, though, my father asked one of my sons what he wanted for his 13th birthday. I told my son to make a list for his grandfather. Well, he did -- an Amazon wish list, on the Amazon account he set up himself months before. Looking over the wishlist, it was clear that he had spent hours picking out games, books, and CDs.

But the boy is even savvier than that. I tried logging on to the wishlist using his e-mail address -- no luck. We have an agreement that he is to share with me his passwords, and he usually does (I know this may change soon, but a mother's gotta try). When I asked what was going on, he told me, "I set up another e-mail address so I don't get spam."

At TRUSTe, we take our Safe Harbor status seriously and work hard with licensees to make sure that they are in compliance with COPPA and similar regulations in the European Union. For more information on how your website can avoid triggering COPPA, join our upcoming webinar (see "Stay Current" below) or call Frank Babbitt at (415) 618-3401 to find out about the TRUSTe Children's Seal.

 
 


Need to know more specifics about the Children's Online Privacy Protection Act (COPPA)? Here are a few online resources:

GigaLaw.com: Federal COPPA Regulations
The GigaLaw.com online law library contains the CFR sections (federal regulations) used to implement COPPA, presented in an easy-to-read, easy-to-navigate HTML format. For full text of the 1998 act, visit http://www4.law.cornell.edu/uscode/15/6501.html (see sections 6501-6506).

Kidzprivacy
Despite its bright colors and cartoony design, the Federal Trade Commission's Kidzprivacy site contains serious information for businesses and consumers. Specific sections for parents, kids, teachers, and website operators all offer concise tips for each audience on privacy, safety, and COPPA compliance -- as well as a host of online resources.

From the "Business Buzz" section, click on "You, Your Privacy Policy, and COPPA" to review the FTC's online COPPA primer for businesses. From the site you can also download the FTC's 24-page COPPA Compliance Toolkit as a PDF file.

TRUSTe Parents' and Teachers' Guide to Online Safety
Recently revised to reflect updates to COPPA, TRUSTe's Parents' and Teacher's Guide is now available free on the Internet. This 18-page guide, published online as a PDF file, describes COPPA in straightforward, concise language and gives consumers information on how to read privacy statements and talk to their kids about privacy issues.

The guide is an ideal resource to pass along to consumers and clients who have questions about privacy issues related to their children. If you would like to cobrand with TRUSTe to publish a print version for your customers, contact Carolyn Hodge at chodge@truste.org or (415) 618-3415.


 
 


Research Shows How to Cut Down on Spam
By Ari Schwartz
Center for Democracy and Technology

Every day, millions of people receive dozens of unsolicited commercial e-mails, known popularly as "spam." For companies and organizations, spam can be a costly problem resulting in difficulties in communication, bandwidth problems, and other unforeseen expenses.

In the summer of 2002, the Center for Democracy and Technology (CDT) embarked on a project to attempt to determine the source of spam. We set up hundreds of different e-mail addresses, used them for a single purpose, and then waited six months to see what kind of mail those addresses were receiving. We were intrigued to see the different ways that e-mail addresses attracted spam -- at differing volumes -- depending on where the e-mail addresses were used.

Web-Posted E-mail Addresses Are a Major Source of Spam
Our analysis indicated that e-mail addresses posted on websites or in newsgroups attract the most spam. In particular, CDT received the most e-mails when an address was placed visibly on a public website. Spammers use software harvesting programs known as "robots" or "spiders" to record e-mail addresses listed on both personal Web pages and institutional (corporate or nonprofit) Web pages. In fact, addresses that had been exposed on the Web and then were subsequently removed stopped receiving large amounts of spam in a relatively short timeframe.

Tips for Preventing Spam From Reaching Your Employees
Currently there is no foolproof way to prevent spam. Based on our research, we recommend that companies disguise e-mail addresses posted in a public electronic place. Webmasters can do this in four ways:

  • Replacing characters in an e-mail address with human-readable equivalents. For example, writing "user@example.com" as "user at example dot com."

  • Replacing characters in an e-mail address with HTML equivalents.

  • Putting e-mail lists up in a graphic format, such as a .gif file. This will allow humans to read it, but robots will not be able to parse through the code to figure out the addresses.

  • Using Web forms for initial contact. This is somewhat impersonal, but it prevents robots from getting addresses.

 

 
 


June brings a host of privacy and security events to cities -- and computers -- near you.

Compliance With European Union Data Protection Requirements: The Safe Harbor and Other Options

Date: Monday, June 2, 2003, 10:30 a.m. - 2:30 p.m.

Location: Oracle Conference Center, Oracle Corporation, 350 Oracle Parkway, Redwood Shores, CA

Overview: American websites serving consumers in the European Union must comply with EU "adequacy standards" for privacy protection of personal data. The U.S. Department of Commerce, together with TRUSTe and Oracle Corporation, have put together this one-day seminar to teach U.S. companies how to comply with EU standards through the Department of Commerce's "Safe Harbor" framework. Topics include self-certification, verification systems, and dispute resolution mechanisms.

The cost of the seminar is free, but participants must register by contacting Scott Beech, U.S. Department of Commerce, at (202) 482-0396.


Technologies for Protecting Personal Information: The Business Experience

Date: June 4, 2003, 8:30 a.m. - 5:30 p.m.

Location: Federal Trade Commission, Washington, D.C.

Overview: Are the technologies that businesses are using to scan their websites for vulnerabilities and privacy violations meeting their needs? This one-day conference will assemble dozens of experts from the government (FTC), nonprofit organizations (TRUSTe, National Consumers League), and corporations (Dell, eBay) to discuss business plans, emerging frameworks, and technologies for protecting consumer information.

For more information, visit http://www.ftc.gov/bcp/workshops/technology/index.html.


Fourth Annual Privacy Law Institute

San Francisco: June 9-10, 2003

New York City: June 23-24, 2003

Overview: The Practicing Law Institute's annual privacy institute focuses on issues of online privacy. This year's institute will include substantial coverage of workplace, consumer, and international privacy developments and a panel discussion of advanced issues in privacy compliance. TRUSTe is a proud sponsor of PLI's Fourth Annual Privacy Law Institute. To obtain detailed information on the institute and to register, visit the following:

San Francisco
http://www.pli.edu/pm.asp?f=rmt3_AD1&id=pr203g001A1003k

New York
http://www.pli.edu/pm.asp?f=rmt3_AD1&ID=pr203g001a6003k


What You May Not Know About COPPA Compliance

Web Seminar

Date: June 17, 2003, 2:00 - 3:00 p.m. EST

Overview: Even though your website may not specifically target children under 13 years old, if you collect age information online, you may be subject to COPPA guidelines. Recent alleged noncompliance by Amazon, as well as FTC settlements with Mrs. Fields and Hershey's, have highlighted the importance of taking COPPA seriously. Could your website be exposing you to this same risk?

To learn more about COPPA, join TRUSTe and Watchfire for a free online seminar. Corporate counsel, privacy managers and website managers will learn about:

  • What makes you subject to COPPPA guidelines?
  • Recent COPPA FTC enforcement actions
  • Responsibilities for all websites that collect age information or target children
  • COPPA action plan
  • Compliance enabling technology
  • Seal certification and Safe Harbor status

The presentation will be followed by a live question-and-answer session.
Register now!

 
 


The May issue of the TRUSTe Advocate marks the introduction of this new feature. Every month, TRUSTe staff will present a practical tip to help website managers and technical staff comply with federal privacy regulations and TRUSTe guidelines.

Tip: To avoid COPPA violations, do not indicate to users that an age restriction exists when collecting personally identifiable information (PII).

COPPA is triggered whenever your website collects both age-identifying information and PII. However, you must not warn users at the point of data collection that an age restriction may prevent them from completing the form. Users must be given the opportunity to input their correct age.

For example, the following language should NOT be used on a form: "I accept and agree to abide by [the] terms [of the website], and I confirm that I am AT LEAST 18 years of age" or "You must be at least 13 years old to use this site." In these examples users know exactly how to falsify their age to circumvent the age restriction.

Similarly, when providing a pull-down menu for users to select their birthdate or age, do not start the list at the minimum acceptable age or year, such as "18" or "1985." Include a full range of ages and dates, thus allowing the user the opportunity to select their correct age or birthdate. Likewise, age should not be collected by asking age-revealing questions such as grade level.

--Jessica Coy, Account Manager

 


TRUSTe would like to congratulate the following new licensees on successfully completing our certification process:

Avatar Group, Capital Confirmation. Copper.net, Destina.ca, Direct 2 Home, Euroteam Trautskogen AS, Faith Online, GDSX, High Performance Networks, Integrity Interactive Corporation, Logitech, Mental Health Association in Greater San Antonio, nCommon Partners, No Logics Inc., Pagewise.com, Playstream, Rievent Technologies, SolidBill, Tenant Abstract.com, The Knot, and Tri-State Dating.com.

 
 


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