We had Google+ enabled on our domain for a while and some year 7's decided to sign up. When they enter their DOB this causes their account to be suspended.
Initially, google support offered the advice that we 'corrected' their date of birth. Nugde nudge, wink wink. They eventually retracted that and told us the only way was to delete the account. But we can't delete the account because it is suspended and you can't delete suspended accounts. Eventually they offered to un-suspend the account if :
For unlocking the account I'll need to receive a direct statement of consent. Meaning I'd need you to send me a message stating "I agree to the terms" or "I am COPPA compliant" type statement to proceed.
I'll repeat the statement so you're aware:
'At your request, we will re-enable this account provided that you verify that doing so is consistent with the terms of your agreement, including your responsibility to comply with applicable laws, including any requirements under the Children's Online Privacy Protection Act (COPPA) that may apply.'
COPPA isn't even UK legislation, but other UK laws may apply.
My questions for the panel :
1. Would you give such an undertaking?
2. How could anyone give such an undertaking when Google are not transparent about the processing they may do do data held by Google. (They have clearly stated that users of Gmail for instance have no expectation to privacy)?
There are more laws than I can count preventing under 13s from using such sites. Nevertheless, COPPA is still applicable here. Online laws are enforced dependent on the owning company's location, so Google can be held liable for anybody you register. Realistically, they probably shouldn't have Google Apps accounts until the reach 13, but I'm sure we can make an exception there, considering google doesn't even ask for age until G+
You could also get COPPA forms for the whole of year 7, and send google a nice big parcel of COPPA Consent forms, but they might prefer to just turn down your business than have their legal team crawl through it all