Sara Collins

In “The Kids Aren’t Alright Online: How to Build a Safer, Better Internet for Everyone,” Public Knowledge argued that age assurance—the practice of verifying an online user’s age—should be a narrow tool, not a policy solution. The most important thing lawmakers can do for children online is require technology companies to design safer products—not deputize parents and children to police systems that were never built with kids’ wellbeing in mind in the first place. But that argument, intentionally, left a question open: when age assurance is appropriate, how should it work?

Public Knowledge joined the Yale Law School Technology Accountability and Competition Project, a division of the Media Freedom and Information Access Clinic, in filing comments in the Federal Trade Commission’s proceeding on the prevalence of commercial surveillance and data security practices that harm consumers. Public Knowledge urges the agency to go beyond codifying the current failed notice and choice framework and build a data protection regime predicated on data minimization, data access rights for consumers, and protection of civil rights.