"If your site has a chat room and no one in your organization sees or is

alerted to the post, then you do not have the requisite actual knowledge

under the Rule. You may be considered to have actual knowledge with respect

to that child: (1) if someone from your operations sees the post in a chat

room; or (2) if someone alerts you to the post."

For the record, I believe I have triggered this rule: http://meta.wikimedia.org/wiki/Talk:Privacy_policy#Lack_of_COPPA

Thanks, George

en|meta|commons: [[User:GChriss]]

On Fri, 08 Sep 2006 11:41:18 -0700 "George Herbert" wrote:

On 9/8/06, Ray Saintonge saintonge@telus.net wrote:

geni wrote:

...

On 9/8/06, Ray Saintonge saintonge@telus.net wrote:

...

Did I miss something? What personal information are we collecting from children?

Ec

the content of userpages.

A new user page is blank. It has no questions asking for personal information, or, for that matter, questions of any sort.

Ec

---

foundation-l mailing list foundation-l@wikimedia.org http://mail.wikipedia.org/mailman/listinfo/foundation-l

From: http://www.ftc.gov/privacy/coppafaqs.htm -----

*38. I operate a general audience site and don't ask visitors to reveal their ages. However, I do have a number of chat rooms. *

*(a) What happens if a child visits my site and posts personal information in a chat room but doesn't reveal his age?*

The Rule is not triggered. It applies to general audience websites if they have *actual knowledge* that a particular visitor is a child. If such a site knows that a particular visitor is a child, then the Rule must be followed with respect to that child. If a child posts personal information on a general audience site, but doesn't reveal his or her age and you have no other information that would lead you to know that the visitor is a child, then you would not have "actual knowledge" under the Rule and would not be subject to its requirements. Collecting a child's age, however, does provide "actual knowledge."

*(b) What happens if a child visits my chat room and announces his or her age?*

If your site has a chat room and no one in your organization sees or is alerted to the post, then you do not have the requisite actual knowledge under the Rule. You may be considered to have actual knowledge with respect to that child: (1) if someone from your operations sees the post in a chat room; or (2) if someone alerts you to the post. At that point, you should delete any personal information that has been posted and either ask the child for a parent's email address for purposes of providing notice and obtaining consent to future postings, or take reasonable steps to block that child from returning to the chat area of the site, whether through screen name blocking, a cookie, or some other means.

If you have monitored chat rooms where the monitors can delete information from posts *before* they are made public, then your monitors can simply strip the child's posts of any personal information before they are publicly posted, thus permitting children to participate in the chat room without the need for obtaining parental consent. This practice is easily applied to "auditorium" style chat in which children pose questions which are screened to a moderator or guest celebrity. -----

It would appear on first glance that though Wikipedia is probably exempt due to being a nonprofit, but that if we were a for-profit then a child posting their own info in a user page (or anywhere else) would fall under the Question 38 examples above.

Though this is undoubtedly a foundation business/legal decision, it would make sense to me that Wikipedia might want to follow that recommended general purpose website guideline above, even if it doesn't apply as a legal requirement because WP is nonprofit. It would seem to be a good general policy.

The FAQ also recommends that general (non child-oriented) and nonprofit sites have privacy policies, even if we aren't required to. That sounds good to me.