Why Vanilla has no Age Gate and you shouldn't help a customer implement one

Vanilla Forums
Vanilla Forums
edited June 2018 in General

What's COPPA?

The Children's Online Privacy Protection Act (COPPA) is a law created to protect the privacy of children under 13. The Act was passed by the U.S. Congress in 1998 and took effect in April 2000. COPPA is managed by the Federal Trade Commission (FTC).

Vanilla is COPPA-compliant out the box because our default Terms of Service state no one under 13 may use a forum. That is the extent of our obligation.

These are the two primary ways a forum owner could violate COPPA:

  1. If a child under 13 makes their age known and moderators do nothing about it. You are obligated to take action if you know a child under 13 is on your site.
  2. They create forum for a game or item which is exclusively or primarily marketed at children under 13 with the expectation that the forum will be used by that target audience.

It's a critical distinction that there is no obligation under COPPA to proactively differentiate users based on their age if there is a reasonable assumption that your site is used primarily by people over 13.

Therefore, if you turn on any sort of age gate-like functionality, you are adding to your liability not decreasing it. You are effectively seeking the knowledge of point #1 above, which means you are then obligated to act on it. Vanilla doesn't have a workflow to manage that effectively beyond banning, so you're creating a problem where none existed.

This is why we removed our Age Gate addon from circulation and should strongly advise customers against adding any sort of ad hoc "solution" for this.

Comments

  • Vanilla Forums
    Vanilla Forums

    The traditional under-13 workflow in other software has been to seek permission from a parent or legal guardian, which is done by soliciting an adult's email address from the minor and sending a second confirmation email. It's basically absurd to assume a minor will truthfully comply with that request, so we have no interest in allowing under-13 users in any capacity or doing services work to accommodate it. Forums are for teenagers or older.

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