• Although Facebook’s minimum age is 13, parents of 13- and 14-year-olds report that, on average, their child joined Facebook at age 12.
• Half (55%) of parents of 12-year-olds report their child has a Facebook account, and most (82%) of these parents knew when their child signed up. Most (76%) also assisted their 12-year old in creating the account.
• A third (36%) of all parents surveyed reported that their child joined Facebook before the age of 13, and two-thirds of them (68%) helped their child create the account.
• Half (53%) of parents surveyed think Facebook has a minimum age and a third (35%) of these parents think that this is a recommendation and not a requirement.
• Most (78%) parents think it is acceptable for their child to violate minimum age restrictions on online services.

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While there is merit to thinking about how to strengthen parent permission structures, focusing on this obscures the issues that COPPA is intended to address: data privacy and online safety. COPPA predates the rise of social media. Its architects never imagined a world where people would share massive quantities of data as a central part of participation. It no longer makes sense to focus on how data are collected; we must instead question how those data are used. Furthermore, while children may be an especially vulnerable population, they are not the only vulnerable population. Most adults have little sense of how their data are being stored, shared, and sold.