The AVPA has submitted comments to the Office of the New York State Attorney General in advance of their rulemaking for the SAFE for Kids Act.
This was a very extensive consultation, demonstrating the rigor the state authorities are putting into this process.
We argued that age assurance is accurate, convenient, cheap, privacy-preserving, secure, effective, inclusive, enforceable and certifiable.
We supported most of the approaches they are considering, including biometric assessement, analyzing user activity, government ID, and bank or credit card information. We warned that attestation from other users has been tried and abandoned by both third-party providers and platforms themselves, and that neither self-attestation nor cognitive tests would be reliable ways to enforce the Act.
We advocated strongly for the use of age assurance solutions that have been audited against international standards such as IEEE 2089.1 and ISO 27566. These would also enforce data minimization and privacy-by-design principles, preventing the retention of any personal data.
And finally, we suggested aligning with FTC requirements under COPPA for Parental Consent, but leaving room for new and innovative methods to be approved, particularly when the IEEE completes its work on a new standard for this process.
You can read our full submission here:
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