- A list of all operators collecting personal information;
- A description of the personal information collected and how it is used; and
- A description of parental rights.
List of Operators
You will need to provide a list of all operators, including third parties, that collect personal information from kids. The list must include the name and contact information for each operator. If you have several operators collecting information, you can provide contact information for only one, as long as that operator agrees to respond to all inquiries from parents about your site or service’s practices. You will still have to list the names of all the other operators, however.
Description of Personal Information Collected
The policy must also describe:
- The types of personal information collected from children (such as name, address, e-mail address, hobbies, etc.)
- How the information is collected (for example, is it collected actively by filling out a form, or passively, through cookies?)
- How the information will be used (marketing to the child, notifying winners of contests, allowing the child to make information publicly available through a forum or chat room, etc.)
- Whether any personal information is disclosed to third parties, and if so, what kinds of third parties and how they use the information.
Description of Parental Rights
Finally, the policy must describe the rights parents have with respect to your collection of personal information:
- That you won’t require a child to disclose any more information that is reasonably necessary to participate in an activity
- That parents can review their child’s personal information, and direct you to delete it, and refuse to allow any further collection or use of personal information from their child
- That parents can agree to the collection and use of their child’s personal information, but still refuse to allow disclosure to third parties unless that is a part of the service (for example, social networks)
- The procedures parents need to follow to exercise these rights.
In the next installment, I will discuss the issues of parental notification and consent.
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