COPPA and UGC in the library

We're working on a feature that will provide reader reviews
in the
OPAC, and allow library patrons to contribute reviews.

We're looking at the implications of the Children's Online
Privacy
Protection Act (COPPA). It seems clear to us that collecting
reviews
from children under 13—not to mention emails for
account-resets—violates COPPA, unless we go through onerous
parental-notification and approval processes. If a 12
year-old users
their review to talk about their hobbies, mention where they
go to
school or—worst case—give their name, we're in violation. We
are, of
course, going to allow libraries to moderate reviews before
they go
live, but COPPA is not just about display. Merely
*collecting* the
information triggers the law. We aren't lawyers, of course,
but it
seems clear to us we can't do it.

*BUT* we seem alone in this concern. Of the various
libraries and
commercial products that allow user-contributed content in
the
catalog, we haven't found any that address this issue.

Does anyone know what's going on here? The OPACs that allow
tagging
and reviewing—do any prohibit under-13s?

Tim

-- 
Check out my library at http:
//www.librarything.com/profile/timspalding


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