Okay; I got a copy. [Thanks to an anonymous source.]
While the header and footer are missing (plus, it's not dated), I've attached the salutation, body and signature tag.
I must say, while I don't have a problem with National attempting to use "technology" this way, their method of delivery (collection)
, in this case, does seem to me, personally, a bad precedent regarding their own youth member privacy policies. Even if --no, especially if-- you are the national council... if you are soliciting any youth member's email address, you'd really, really, really, should have their parent's permission, first. Just because "A Scout is trustworthy."
, that does not override a parent's right to determine who should get their child's e-mail address, and for what purpose.
Now, IANAL (a.k.a., "I am not a lawyer"
)... But, IMO, if you are soliciting the email address (or proposing ANY form of online interaction) with anyone under the age of 13
, you'd best be in compliance with the Children's Online Privacy Protection Act and Rule (COPPA)
. Admittedly, the law can sometimes seem a bit grey, as there are some specific exclusions. But still, the purpose and intent of this law is, first and foremost, to ensure the opportunity for parental consent to be the overriding prerequisite in preventing, allowing for, or ceasing, the collection of personal information for the purpose of any online interaction with a child under the age of 13.
COPPA wrote:Personal Information
The Children's Online Privacy Protection Act and Rule apply to individually identifiable information about a child that is collected online, such as full name, home address, email address, telephone number or any other information that would allow someone to identify or contact the child. The Act and Rule also cover other types of information -- for example, hobbies, interests and information collected through cookies or other types of tracking mechanisms -- when they are tied to individually identifiable information.
Verifiable Parental Consent
Before collecting, using or disclosing personal information from a child, an operator must obtain verifiable parental consent from the child's parent. This means an operator must make reasonable efforts (taking into consideration available technology) to ensure that before personal information is collected from a child, a parent of the child receives notice of the operator's information practices and consents to those practices
Let us still
consider the possibility of still
not knowing the full story here... We were not there; we don't know what the form looks like. So, we really do not know the full context of this situation. There is the possibility of an attachment, or some other kind of specific instructions, being included in the "welcome packet" that was referenced in the original post. E.g., Maybe, the form itself (which we have not seen, yet) contains a statement prohibiting the collection of e-mail addresses from Scouts under the age of 13.
But, so far, I can say this much:
If it were my signature on the above letter, you can bet your life I would have addressed COPPA before I signed anything. If anybody comes up with anything else (i.e., a copy of the form); or, if you have any ideas, views, or references (pro or con), I'd love to hear your thoughts.
Then again, I wouldn't be sending out such a letter in the first place... at least, not without it going to the Scout's parents, instead... rather than trying to collect this information via the Scoutmasters while at Summer Camp, i.e., taking the parents out of the loop.
While this letter does well in explaining appropriate security and handling measures; but, it fails to disclose whether or not a third-party (even if a contractually "trusted" agent) will be involved in the "research" -- that alone is a yellow flag. (Using a trusted agent in such "research" is common practice; but, so is hiding that fact.)
More importantly though, the failure to even hint at parental consent gives me legitimate cause to distrust the entire "research project".
Of course, they could just pay Mark Zuckerberg (see: Data_mining) a small fortune and get whatever "research" data they want.