Matt went into his son’s bedroom one evening and found him stretched out on his bed typing on his laptop. “Doing your network?

SCENARIO

Please use the following to answer the next QUESTION:

Matt went into his son’s bedroom one evening and found him stretched out on his bed typing on his laptop. “Doing your network?” Matt asked hopefully. “No,” the boy said. “I’m filling out a survey.”

Matt looked over his son’s shoulder at his computer screen. “What kind of survey?” “It’s asking Questions about my opinions.”

“Let me see,” Matt said, and began reading the list of Questions that his son had already answered. “It’s asking your opinions about the government and citizenship. That’s a little odd. You’re only ten.”

Matt wondered how the web link to the survey had ended up in his son’s email inbox. Thinking the message might have been sent to his son by mistake he opened it and read it. It had come from an entity called the Leadership Project, and the content and the graphics indicated that it was intended for children. As Matt read further he learned that kids who took the survey were automatically registered in a contest to win the first book in a series about famous leaders.

To Matt, this clearly seemed like a marketing ploy to solicit goods and services to children. He asked his son if he had been prompted to give information about himself in order to take the survey. His son told him he had been asked to give his name, address, telephone number, and date of birth, and to answer Questions about his favorite games and toys.

Matt was concerned. He doubted if it was legal for the marketer to collect information from his son in the way that it was. Then he noticed several other commercial emails from marketers advertising products for children in his son’s inbox, and he decided it was time to report the incident to the proper authorities.

How does Matt come to the decision to report the marketer’s activities?
A . The marketer failed to make an adequate attempt to provide Matt with information
B . The marketer did not provide evidence that the prize books were appropriate for children
C . The marketer seems to have distributed his son’s information without Matt’s permission
D . The marketer failed to identify himself and indicate the purpose of the messages

Answer: C

Explanation:

Matt’s decision to report the marketer’s activities is based on his suspicion that the marketer violated the Children’s Online Privacy Protection Act (COPPA), which is a federal law that regulates the online collection, use, and disclosure of personal information from children under 13 years of age1. According to COPPA, operators of websites or online services that are directed to children or knowingly collect personal information from children must:

Provide notice to parents about their information practices and obtain verifiable parental consent before collecting, using, or disclosing personal information from children12.

Give parents the choice of consenting to the operator’s collection and internal use of a child’s information, but prohibiting the operator from disclosing that information to third parties (unless disclosure is integral to the site or service, in which case, this must be made clear to parents)12. Provide parents access to their child’s personal information to review and/or have the information deleted and give parents the opportunity to prevent further use or online collection of a child’s personal information12.

Maintain the confidentiality, security, and integrity of information they collect from children, including by taking reasonable steps to release such information only to parties capable of maintaining its confidentiality and security12.

Retain personal information collected online from a child for only as long as is necessary to fulfill the purpose for which it was collected and delete the information using reasonable measures to protect against its unauthorized access or use12.

Establish and maintain reasonable procedures to protect the confidentiality, security, and integrity of personal information collected from children12.

In Matt’s case, he did not receive any notice from the marketer about the survey or the contest, nor did he give his consent for the collection or disclosure of his son’s personal information. He also did not have any access or control over his son’s information or the ability to prevent further use or collection. Moreover, he noticed that his son’s information seemed to have been shared with other marketers, as evidenced by the commercial emails in his son’s inbox. These actions indicate that the marketer did not comply with COPPA’s requirements and may have exposed his son’s information to unauthorized or inappropriate parties. Therefore, Matt decided to report the marketer’s activities to the proper authorities, such as the Federal Trade Commission (FTC), which enforces COPPA and can impose civil penalties for violations13.

Reference: 1: Children’s Online Privacy Protection Act | Federal Trade Commission, 1. 2: 16 CFR Part 312 C Children’s Online Privacy Protection Rule, 3. 3: Children’s Online Privacy Protection Act – Wikipedia, 2.

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