Let me try once more. The change I suggest to the IAOC IS:
Really, no.
Keep in mind that COPPA is only concerned with PII, so the only thing it
would affect is whether 12 year olds can join mailing lists and create
datatracker accounts. We do not know or care who is looking at the web
sites and mail archives.
If you say you allow under-13's to sign up at all, COPPA deliberately
requires all sorts of record keeping that in practice means we'd have to
hire one of a handful of specialist COPPA compliance firms. It is not
adequate to say we asked her mother who said it's OK.
Just leave the boilerplate alone. It avoids significant legal exposure,
and in practice limits nothing.
R's,
John
We do not knowingly collect personally identifiable information from, or
target our websites to, children under the age of 13. In accordance
with the United States Children’s Online Privacy Protection Act of 1998,
if we discover that a child under 13 has provided us with personally
identifiable information, without the consent and participation of a
parent or guardian, we will remove it from our systems.