Privacy and Youth Protection
The Internet is perceived as a threat by some individuals, and they are
vehemently opposed to having their images or personal information available
to others. This perception is not unjustifiable, as demonstrated by periodic
media coverage of predators who exploit the Internet to select, locate, and
contact their victims.
Collecting Personal Information
Councils are urged to be discreet when collecting personal information
via their Web sites. Privacy is a delicate issue on the Internet, and many
people are reluctant to use sites or interfaces that require them to provide
personal information such as their name, address, telephone number, e-mail
address, etc. We recommend that councils avoid using the Internet to gather
this information about users unless it is necessary to accomplish the user's
goals. For example, you would have to request a telephone number and contact
name from an organization that wishes to be contacted about starting a unit,
but it should not be necessary that they provide this information merely in
order to read information about starting a unit.
It is especially important to treat contact information carefully: contact
information should be used only for the purpose for which it was provided. It
is unethical and in some cases illegal to use this data for any solicitation
or communication outside the context in which it was provided. The issue is
particularly serious regarding contact information for children under 13.
The Federal Trade Commission recommends that charities and companies that
collect personal information from online visitors use the following set of four
standards—known as "fair information practices"—in creating privacy
policies to post on their Web sites:
- Notification. Visitors to the Web site should be notified as to what
personal information is being gathered, how that information is used by the
organization, and with what third parties, if any, the organization will share
- Choice. Visitors should be provided with a means by which to contact
the organization or take other actions to ensure that their personal information
is not shared, if they so choose.
- Security. Users of the site should be notified of the means by which
the organization protects personal information, including protection from any
misuse, alteration, or access by unauthorized users. Organizations should strive
to ensure that the same level of privacy protection is extended by any third
parties with whom they share individuals' personal information.
- Access. Web site users should have reasonable access to any personal
information about themselves that the organization holds, as well as a means of
correcting or amending the information if it is inaccurate
Children's Online Privacy Protection Act
While the Children's Online Privacy Protection Act (COPPA) applies to commercial
Web sites, it provides sound guidance for any Web site that is intended for use
by children under 13. Therefore, if your Web site collects any personally
identifiable information from or about children, you should review and consider
complying with this legislation. The full text of COPPA can be found online at
http://www.ftc.gov/ogc/coppa1.htm. Information on how to comply with
the act is available at the FTC's "Kidz Privacy" Web site at
Providing Personal Information
Regarding e-mail specifically, there remains the potential for a flood of
correspondence to overwhelm the council staff if e-mail addresses are published
on the Web site. The presence of e-mail addresses on a majority of council sites
would seem to suggest that this potential has not become an actual problem, but
a council should be prepared to react, possibly by removing contact from its site
or even shutting down the mailbox, if problems do occur.
Contact information should only be published for a reason—specifically,
whether there is a valid need for the members and/or the public to speak directly
with a given individual because of that person's role in the organization. The
council's policy should address these three groups separately, for these reasons:
Youth Participants and Parents
Contact information for youth participants should never be provided on the
Internet. If the council wishes to maintain contact information for youth
participants, it is strongly recommended that these lists are kept entirely
Concerning e-mail addresses in particular, councils should be
aware that there are computer programs that crawl the Internet compiling lists
of e-mail addresses that appear on Web pages. These lists are often sold to e-mail
marketers who regularly send unsolicited advertisements, primarily for pornography
and pyramid schemes. It is recommended that councils that wish to provide e-mail
contact information utilize techniques to prevent or minimize this unfortunate
side effect (such as "escaping" characters or using CGI scripts that maintain
the actual addresses in a safe location).
Contact information for adult volunteers should be treated with caution, as it
is likely this information will be personal in nature (home addresses, residential
telephone numbers, and private e-mail accounts). If this information is made available
on the Web site, it would be preferable to provide it in a password-protected area
of the Web site to which the general public has no access. Exceptions may be made
for those volunteers whom it would be necessary for third parties to contact in
order to obtain information about joining, starting, or supporting individual units.
It is strongly recommended that this information be published only after obtaining
written authorization, and that these individuals should know that they can (and how
to) request the prompt removal of their information at any time.
If a third-party exploits information such as individual telephone numbers and
e-mail addresses to harass or threaten employees, this could result in legal action
being taken against the council. For that reason, it is recommended that the council
provide only its main telephone number and generic e-mail addresses
"email@example.com", etc.) on its Web site.
Personal contact information—home telephone numbers, addresses, and private
e-mail accounts—for council employees should be treated with the same discretion
as that of adult volunteers.
Photographs and Names
A council should obtain permission before publishing any photographs on the
Internet except those taken by council employees.
Because some states have privacy laws that could be implicated if a child's
photograph is published on the Internet without his parents' permission, ownership
of the image alone does not carry with it the right to publish it. Therefore,
the council should obtain permission from any person who is the subject of a
photograph before displaying their image or likeness on the Internet.
When using photographs of members, especially youth, it is also important to
consider their safety and privacy when choosing captions or ancillary text. Some
councils have established policies that no names will be associated with photographs
at all, whereas others have a "first name only" policy for youth under a certain
age, but allow the full names of adult leaders and older Scouts to be published.