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COPPA Explained | FPHQ's Protection Measures | Parental Consent Issues
The adoption of COPPA was in direct response to the lack of industry compliance with the law as articulated by the FTC in the KidsCom/CME letter. In June 1998, the FTC presented its Privacy Online Report to Congress, documenting the online collection of personal information from children. The FTC rearticulated its prior concerns, that collection of personal information from a child under the age of 13 without informed parental consent would be a deceptive trade practice. The FTC reported to Congress that even in chat rooms, children innocently and without request may reveal where they live or go to school or their real e-mail addresses. The FTC informed Congress that parents need to understand the risks and consent to any such collection and disclosure of personal information. Congress apparently agreed, and wasted no time in acting on the FTC's report. Within months COPPA was law.
COPPA requires that commercial websites obtain verifiable parental consent before collecting personal information from a child under the age of 13 (age 12 and under). A failure to obtain such consent is an unfair and deceptive trade practice. COPPA took effect on April 21, 2000.
COPPA applies to commercial websites, online services "targeted at children" and any online service operators with actual knowledge that they collect personal information from a child. (Actual knowledge can be as simple as a child sharing their grade or age in a monitored general audience chatroom on your client’s site, or can be supplied by an email or phone call from concerned parents who object to the collection practices on behalf of their child.) Personal information includes such items as full name, home address, e-mail address, telephone number, social security number or any other information that the FTC determines "permits the physical or online contacting of a specific individual."
The FTC promulgated the regulations implementing COPPA on October 20, 1999. The regulations require covered operators to:
- Provide notice on the website of what information is collected from children, how information is used and the website operator's disclosure practices for such information (notice this applies to all information, not just "personal information");
- Obtain verifiable parental consent (which requires more than a mere e-mail consent from the parent) to collect, use or disclose children's personal information before it is collected from the child, with certain exceptions and special rules for newsletters and internally used information;
- Upon request, provide parents with a description of the types of information collected from their child, or the actual information obtained from their child, and the opportunity to refuse to permit the further use, maintenance or future collection of the child's personal information. Thus,
in addition to having to obtain initial consent from the parents, if a parent withdraws consent at any time, the operator must remove that child's personal information from the system;
- Cease conditioning the child's participation in games, contests or any other activity upon the disclosure of more information than is reasonably necessary to participate, including permitting parents to allow the site to collect personal information but refusing to let the site share the information with third parties; and
- Maintain reasonable procedures "to protect the confidentiality, security, and integrity of personal information collected from children."
COPPA Explained | FPHQ's Protection Measures | Parental Consent Issues
Fastpitch Headquarters is committed to protecting the privacy of our children. The collection of personal, academic and athletic information of players is essential to the recruiting process. Fastpitch Headquarters has implemented the following practices and guidelines:
- No children under the age of 13 are allowed to become an individual member of Fastpitch Headquarters.
- Children between the ages of 13 through 17 who wish to become an individual member of Fastpitch Headquarters must submit a signed Parental Consent Form (see below).
- Teams submitting Team Player Profiles are not allowed to include players under the age of 13 in their submission unless the parents of the under 13 child submit the Parental Consent Form (see below). If an under 13 child is submitted on the Team Player Profile without the signed form, FPHQ will delete that player's information as soon as detected.
- Tournaments submitting Tournament Player Profiles are not allowed to include players under the age of 13 in their submission unless the parents of the under 13 child submit the Parental Consent Form (see below). If an under 13 child is submitted on the Tournament Player Profile without the signed form, FPHQ will delete that player's information as soon as detected.
- Only verified college coaches will have access to the Player Profile databases. This is a manual process that insures that only legitimate college coaches, or their authorized representatives (athletic directors, for example), are viewing player information.
- Only verified college coaches and tournament directors will have access to the Team Profile databases. The team official who entered the Team Profile must notify FPHQ which tournaments they are participating in, and only those tournament directors receive the team's profile data for the purpose of providing it to the college coaches at the tournament.
- All player profile information, whether submitted via Player, Team or Tournament Profiles, is stored on secured servers and is password protected. Player information is not given to any non-members of FPHQ, or to any third parties, unless specified above.
COPPA Explained | FPHQ's Protection Measures | Parental Consent Issues
Eventhough we are not required by law to do this, FPHQ requires that parental consent forms be submitted for all individual player memberships for children between the ages of 13 through 17. If a player is 18 years old, they do not need to submit this form.
Download Under 18 Parental Consent Form in .pdf format
This form is required for all under 13 players whose information is submitted to FPHQ via Team Player Profiles and/or Tournament Player Profiles. If this form is not received, the child's information will not be included in the online database.
Download Under 13 Parental Consent Form in .pdf format
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