Fwd: COPPA and the Club's Websites and Lists

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From: Dave Simon <[log in to unmask]>
Subject:      COPPA and the Club's Websites and Lists


Based on discussions with legal counsel, the following policy has been
established for compliance with COPPA, the Children's Online Privacy Protection
Act of 1998.  Please let me know if you have any questions.  Thanks.

Dave
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The Children's Online Privacy Protection Act of 1998 and the FTC's implementing
regulations (collectively, "COPPA") took effect on April 21, 2000.  COPPA is
intended to protect the privacy of children under the age of 13, primarily in
their activities on sites (websites, lists, chats, etc) that are targeted at
children.  If an operator of a site learns that a user is under 13, the operator
must obtain parental permission before collecting or disclosing any personal
information about the child.  Without permission, an operator must remove all
personal information (name, address, phone, email address) about the child from
the site and the operator's archives.

COPPA has been discussed with the Sierra Club's legal counsel and the following
impact on our websites and email lists has been identified.  No changes will be
made to the website or email list Terms and Conditions documents.

Impact on Club Websites

Because our websites are not targeted at children and do not support chats or
other functions in which a child could provide personal information, COPPA does
not presently have an impact on our websites.
Impact on Club Email Lists

If a list participant identifies his/herself as a child under 13, please notify
[log in to unmask]  The listmaster will attempt to obtain parental
permission so that the child can continue to participate in the email list.  In
the meantime, the child will be removed from the email list.  The listmaster
will also send the following message to the child:
"Thank you for your interest in the Sierra Club and our efforts to protect the
environment.  Due to the Children's Online Privacy Protection Act of 1998, your
continued participation on the email list to which you were subscribed requires
the permission of your parents.  This letter should say, "My child, ______, has
my permission to participate on Sierra Club email lists."  Please have your
parents send the letter to the Sierra Club (attention Email Lists, 85 Second St,
2nd Floor, San Francisco, CA  94105).  When we receive and confirm your parent's
permission letter, we will add you back to the email list."

If it turns out that the additional workload of parental permission verification
is significant, we may revise this policy.
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