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Created October 21, 2020 16:52
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Coppa.md

🧒 COPPA Procedure

👉 Situations involving viewers under 13, or suspected of being so.

🔍 Background

Noone under the age of 13 can be knowingly allowed to message, communicate or otherwise share data via any online platform that Coding Garden currently uses. As this violates Discord / Twitch ToS, the most direct explanation is that CJ is at risk of having his channel/discord deleted were he not to take this action.

This all stems from child protection laws in the US (COPPA) and elsewhere. Please note that knowingly communicating directly with a child online, or coming into possession of their personal data, also exposes you to significant legal risk personally as well.

See also: COPPA in 📜 The Rules

⚖️ Policy

  • Noone under the age of 13 is permitted to use the Twitch live chat or Discord server (or any future platforms)
  • These bans should be described as "not allowing access to anyone under 13" rather than a ban of any specific person.
  • Anyone known to be under 13 should be instantly banned
    • Any claims to be under 13 (even a joke/meme) should be taken at face value. Unless you already know their age for certain (personally or e.g. from a professional LinkedIn profile).
    • Anyone suspected of being under 13 should be banned, unless it can be definitely established (from publicly available information) that they are older
  • Personal data relating to children must be deleted

▶️ Procedure

1. 🕵️ Consult with the rest of the mod team.

  • 🤔 Discuss the situation!
  • Attempt to definitively establish their age from publicly available information such as social media accounts linked from their profile.
  • If this cannot be done (e.g. their profile photo looks anywhere from 11-15) then they must be treated as under 13.
  • 🛑 Proof of age and personal info MUST NOT be requested from a suspected child. Any received must be destroyed.

2. 💾 Save logs, links and user details

  • ℹ️ Important: save Discord message links for all relevant messages, and user details. Discord's report form will not submit without a valid link to any of the user's messages
  • 🎗 Collect everything you need for the report in step 5 before proceeding. Banning users can render them inaccessible.
    • 👉 Read ahead first if you are unfamiliar with this process

3. 🚫 Issue a permanent ban to all known accounts.

  • 🛑 Do not delete Discord messages at this stage. Functional message links are required for the report.

4. 💬 Inform them of their exclusion using the message template below

  • 👁‍🗨 A neutral mod with no prior message history should be chosen to send the notice if they have previously had contact with the mod team.
  • 🛑 DO NOT disclose the reason / information / message that identified them as under-13
    • This would invite a back and forth with personal info shared
    • This may itself constitute personal data of a child
  • 🚫 Block their accounts so they cannot message you. Close and block all DMs.
    • This is to protect yourself. Continuing to speak with a young child puts you personally in a risky position.

5. ❗ Report their accounts as underage to the platforms directly.

  • Discord - dis.gd/request
    • Select: Trust & Safety > Child Safety > User is under 13
    • Fill in and submit the 📋 Discord report template
  • Twitch - User's profile > […] > Report
    • Select: Where is the problem? In a chat message > Give me more options... > They're underage (12 or younger)
    • Fill in and submit the 📋 Twitch report template
  • YouTube
    • YouTube is yet to achieve COPPA compliance and lacks a reporting mechanism. [Review as and when this changes]

6. ⏳ Wait for email responses to your reports

  • 📅 Usually 1-3 days
  • 📧 Share the responses with the rest of the mod team

7. 🗑️ Delete messages, personal data

  • 📝 Record the account usernames in the incident log and copies of reports and their responses.
    • ❌ Delete all other personal data you may have collected
  • 🕵️ Review their message history before deleting it for anything that could be needed for further moderation (e.g. if there is a group of under-13 viewers who all need to be identified)
    • 🧹 Discord message history should now be deleted where appropriate

💬 COPPA message

Hi,

It has come to our attention that you may be under 13 years of age.

Unfortunately Coding Garden cannot allow anyone under 13 to use the live chat or Discord server. Twitch and Discord have explicitly disallowed users under 13 to use their services and do not have a mechanism to give parental consent for viewers under 13. If someone is found to be under 13 we have to report it or risk being removed from the platforms. This is because of child protection laws in the US and elsewhere.

Any accounts known to be under 13 will not be able to send messages in the live chat or use the Discord server.

We know this is not fair and is a bit discouraging, but we have to do everything in our power to follow the terms of service of Twitch and Discord. If we knowingly allowed a TOS violation, this could lead to the entire channel and server being reported and taken down. If that were to happen, there would be no more Coding Garden to watch.

We are really sorry for this. This action is not directed at you personally, this action applies to any viewer found to be under the age of 13.

- Coding Garden Mod Team

📋 Discord report template

ℹ️ The report form will not submit without a valid link to any of the user's messages - even if not relevant for the report. A work-around if you're completely stuck without one (but with an appropriate explanation in your message to Discord) is to submit: https://discord.com/channels/000000000000000000/000000000000000000/000000000000000000

Discord support,

RE: Report of user under 13 - COPPA "actual knowledge"

User-ID: [USER'S 18 DIGIT USER ID]
Name: [USER#1234]

Discord server: CodingGardenWithCJ (451779463370375170)
This server is for the viewer community of Coding Garden with CJ - a YouTube channel and Twitch stream for educational content, programming and web development.

Background:
[DETAILS OF HOW THEY WERE DETERMINED TO BE UNDER 13]

As per our own procedure for handling COPPA and Child safeguarding, they were immediately banned/blocked from all platforms and services Coding Garden exists on.

This report is to comply with Discord TOS and US law (where Coding Garden is based) for handling users found to be under the age of 13 - COPPA "actual knowledge".

Regards,
[YOUR DISCORD ID] - moderator at CodingGardenWithCJ

📋 Twitch report template

Twitch support,

RE: Report of user under 13 - COPPA "actual knowledge"

[DETAILS OF HOW THEY WERE DETERMINED TO BE UNDER 13]

As per our own procedure for handling COPPA and Child safeguarding, they were immediately banned/blocked from all platforms and services Coding Garden exists on.

This report is to comply with Twitch TOS and US law (where Coding Garden is based) for handling users found to be under the age of 13 - COPPA "actual knowledge".

Regards,
[YOUR TWITCH ID] - moderator at twitch.tv/codinggarden
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