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Author Topic:   COPPA
Richard Insley
Member

Posts: 233
Registered: Oct 2000

posted 12-07-2000 08:47 PM     Click Here to See the Profile for Richard Insley   Click Here to Email Richard Insley     Edit/Delete Message
Does anyone have, or have you seen a bank website that is covered by and compliant with COPPA?

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Andy Z
Member

Posts: 862
Registered: Oct 2000

posted 12-08-2000 09:04 AM     Click Here to See the Profile for Andy Z   Click Here to Email Andy Z     Edit/Delete Message
I know of none that are compliant with it, and none that try to collect information from kids.

I fear though, that many of us are subject to it without realizing it.

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Andy Zavoina
Opinions stated are not necessarily that of my employer.

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Mary Beth Guard
Moderator

Posts: 259
Registered: Oct 2000

posted 12-08-2000 11:47 AM     Click Here to See the Profile for Mary Beth Guard   Click Here to Email Mary Beth Guard     Edit/Delete Message
Love a challenge! I haven't found any that are l) subject to COPPA and 2) in compliance with COPPA, but I found a wonderful site that I believe should be complying, but does not appear to be. I believe it should be complying because it has an ask an expert form that gathers personal information, etc. What do you think?
http://www.kidsbank.com/

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Andy Z
Member

Posts: 862
Registered: Oct 2000

posted 12-08-2000 02:08 PM     Click Here to See the Profile for Andy Z   Click Here to Email Andy Z     Edit/Delete Message
Since COPPA includes "individually identifiable information about a child that is collected online, such as full name, home address, email address, telephone number or any other information that would allow someone to identify or contact the child", I would say that "Ask Mr. Money" qualifies. The child's name is a required field.

Related, whitehouse.gov asks for the kids info as well and has been cited as noncompliant.

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Andy Zavoina
Opinions stated are not necessarily that of my employer.

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Alittlebirdy
unregistered
posted 12-26-2000 04:04 PM           Edit/Delete Message
I think the Disney website is covered by COPPA and is intended to comply. This is per their privacy guru at a Wash DC seminar last month concerning the topic. Her name was Alden LNU.

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Richard Insley
Member

Posts: 233
Registered: Oct 2000

posted 12-27-2000 07:50 PM     Click Here to See the Profile for Richard Insley   Click Here to Email Richard Insley     Edit/Delete Message
So let's see.......

In three weeks we've indicted the White House, failed to locate a single bank that is covered & compliant and determined that Mickey Mouse MIGHT be compliant!

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Susan C.
unregistered
posted 01-08-2001 07:12 PM           Edit/Delete Message
Since COPPA prohibits collecting information from children without first obtaining parental consent, I think that puts the onus on the bank to ensure that someone submitting an online application (to open an account, apply for a loan, sign up for internet banking etc.) affirms that he/she is at least 18 years old.

I noticed that Wingspan has this on its online application (https://marketing.wingspanbank.com/IBServlet), but a lot of banks do not.

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Andy Z
Member

Posts: 862
Registered: Oct 2000

posted 01-09-2001 09:20 AM     Click Here to See the Profile for Andy Z   Click Here to Email Andy Z     Edit/Delete Message
You are absolutely correct, Susan.

Initially I thought this was just for sites that targeted children, but that is not the case.

I have added an "Must be 18 or older" warning to all my online applications.

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Andy Zavoina
Opinions stated are not necessarily that of my employer.

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Susan C.
unregistered
posted 01-18-2001 10:34 PM           Edit/Delete Message
Upon further review, I noticed that the info gathering page must be targeted toward children or responses from children are expected. I should have read more before submitting my previous post. However, I still think having the applicant affirm he/she is at least 18 is a good idea.

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Andy Z
Member

Posts: 862
Registered: Oct 2000

posted 01-18-2001 11:37 PM     Click Here to See the Profile for Andy Z   Click Here to Email Andy Z     Edit/Delete Message
I really tend to agree with your original post. On the FTC's site that addresses "How to Comply With COPPA", they state COPPA applies to a site "that collects personal information from children or if you operate a general audience Web site and have actual knowledge that you are collecting personal information from children".

If your online application includes their age, you have actual knowledge. I have heard an inference to this effect from a senior regulatory official. Whether all agencies adopt this or enforce it remains to be seen. But it is an easy risk to mitigate, "Must be 18 or older to apply (online)".

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Andy Zavoina
Opinions stated are not necessarily that of my employer.

[This message has been edited by Andy Z (edited 01-18-2001).]

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Richard Insley
Member

Posts: 233
Registered: Oct 2000

posted 01-19-2001 06:56 AM     Click Here to See the Profile for Richard Insley   Click Here to Email Richard Insley     Edit/Delete Message
I agree with Andy's take on this--and besides, how many banks want to make loans to or contract with 12 year olds?

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