Children's Online Privacy Protection Act (COPPA)

SCREEN ACTORS GUILD PRIVACY POLICY IN REGARD TO CHILDREN UNDER THE AGE OF 13

This privacy policy in regard to children under the age of 13 (“Children’s Privacy Policy”) relates to the web site at www.sag.org (the “Site”). The Site is provided by Screen Actors Guild, Inc. (the “Guild” or “ us”) located at 5757 Wilshire Blvd., Los Angeles, CA 90036-3600, ATTENTION: Legal Department/Website Terms of Use and Privacy Policy, email webmaster@sag.org and the name of the Guild’s agent is Duncan Crabtree-Ireland, General Counsel, located at 5757 Wilshire Blvd., Los Angeles, CA 90036-3600.[SG1] This Children’s Privacy Policy is incorporated by reference into the Terms. Portions of this Children’s Privacy Policy pertain to the iActor online casting area of the Site and other functionality available only to Guild members in good standing. The Guild encourages parents and legal guardians to become involved in the online activities of their children and to discuss the child’s use of the Internet and disclosure of information to any parties. If you are 13 years old or younger, you must provide your parent’s or legal guardian’s email address or other contact information from which the Guild may obtain your parent’s or legal guardian’s consent before you give out any information on the Site. Please have your parent or guardian complete the Consent of Parent or Guardian form listed above and return it to us as instructed on the form.

We recognize that some of our members are under the age of 13 and yet want to participate in all of the benefits the Guild offers via the Site. Full participation in the Site requires the collection and submission of personally identifiable data. Rather than blocking or restricting access to the Site to those 13 years of age or older, the Guild has opted to make its on line services available to all of its members. In doing so, the Guild desires to comply with the requirements of The Children’s Online Privacy Protection Act (COPPA). Effective as of April 2000, COPPA was established by Congress to protect children’s online privacy. COPPA requires that Web site operators adhere to specific guidelines regarding the collection and handling of personally identifiable information about children under the age of 13. For more information about COPPA and your child’s rights to online privacy, visit the FTC’s Kids’ Privacy Web site for parents at http://www.ftc.gov/bcp/conline/edcams/kidzprivacy/adults.htm. COPPA requires that we provide parents of our younger members with certain information and obtain parental consent prior to permitting members under the age of 13 to access and use the Site.

• A. What types of information do we collect about children?
  1. Children can view content on the non –members portion of Site without any personal information being collected. We do not collect personal information from children unless they register on members only portion of the Site.
  2. During our registration process we collect a child’s first name and last name, parent's e-mail address, parent’s telephone number, child’s birth date, Guild member number, last four digits of the child’s social security number and password. The child is also asked to provide a password hint, in the event the password is lost or forgotten. We collect birth dates to validate the ages of our guests, including children. We also collect a child’s-mail address from a parent for the purpose of sending the child e-mail related to their activity with the Guild and on the Site. Note that all sites that are directed to children under 13 are prohibited by law from conditioning a child’s participation in an online activity on the child providing more personal information than is reasonably necessary.
  3. We may collect personal information from parents in order to allow kids to participate in certain features located on our Web sites. These features may include job boards, instant message chatting, sending e-mail, sending resumes, posting on message boards, interacting with third parties, and other similar activities. In the course of a child’s participation in these features, a child may also provide us additional information about himself or herself, such as the contents of his or her chat or message board postings.
  4. If a parent allows us to collect personal information about their child, we will permit the child to access and use the iActor online casting area of the Site. On iActor a child may enter resume data about himself or herself, such as name, address, professional experience, representation, special skills and training, physical characteristics, portrayable age range, head shots, sound clips, video clips, and other data relevant to his or her potential employment as an actor (“Resume Data”). Resume Data may also include data the Guild enters automatically from a child’s member records. Please see the iActor Member Guide and Tutorial, as it may be updated from time to time (the “iActor Member Guide”), for more information on the types of data collected in the iActor portion of the Site. We recommend that our members not disclose their home address, home telephone number or other personal information they may not want generally disclosed. This is of particular concern in the case of children. Consider posting the contact information for your child’s agent or manager instead or the parent’s office contact information. If you do not have an agent or manager, consider obtaining a post office box and an answering service.
     
• B. How do we use and share the personally identifiable information that we have collected about children?
  1. To personalize communications from the Guild to a child (such news and updates), we may use the child’s name and mailing address. We may collect a child’s e-mail address in order to send a newsletter or other communications relating to his or her membership in the Guild. In addition, personal information regarding a child may be disclosed in the course of a child’s participation in certain interactive features such as message boards.
  2. The iActor portion of the site is intended to serve as a “job board.” On the iActor portion of the site, Resume Data is specifically intended to be made available to third parties such as casting directors, producers, directors, agents and others and may be used by such parties to contact the child and evaluate his or her potential employment. Such third parties can search and view Resume Data of participating Guild members and Guild members may communicate directly with such third parties, including transmission of resume data to them. You hereby authorize the Guild to make all such disclosures of the child’s Resume Data to third parties as stated above and contemplated in the iActor Member Guide. Third parties will be required to agree that they may use such information only to contact the child or his or her representative for legitimate employment opportunities and to keep such information confidential and secure, but the Guild cannot make any guarantees of compliance by third parties and the Guild will not be responsible in any manner should such parties fail to comply with such agreement.
  3. Except as otherwise disclosed in this Policy, we do not share any information about a child with any affiliated entity or with any third parties unless the disclosure is reasonably necessary: to comply with law, including, for example, to comply with a court order or subpoena; to enforce our Terms of Use, or site rules; or to protect the safety and security of our guests and our Web sites.
     
• C. How do we notify and obtain consent from parents for the collection of information from a child?
  Before allowing a child to use a feature of our Web sites that might result in the disclosure of the child’s information to third parties on the Internet, we require the parent to consent in writing to this Children’s Privacy Policy, our Terms of Use and our more general Privacy Policy and to provide us with evidence confirming their identity, such as a copy of a valid driver’s license. This information is retained by us as evidence that we received parental consent.
  
• D. How can parents access, change or delete personally identifiable information about their child ?
  1. At any time parents can refuse to permit us to collect further personal information from their child and can request that any personal information we have collected be deleted from our records. We use two methods to allow parents to access, change, or delete the personally identifiable information that we have collected from their child.
     • (a) A parent can access, change, or delete his or her child’s personal information by logging on to the child’s account on the site, http://www.sag.org. The parent will need to have their child’s member name and password. If your child has forgotten the password, click on ‘Forgot Password?” link on the home page and follow the instructions
     • (b) A parent can contact our customer service department to access, change, or delete the personal information that we have collected from his or her child by sending an e-mail to webhelp@sag.org. Please include the child’s member name and the parent's e-mail address in the e-mail so that we can better assist you with your inquiry or request.
       
• E. How will we notify parents if our Children’s Privacy Policy changes?
  We may amend our Children’s Privacy Policy at any time. We will provide parents notice by e-mail of any material changes in the way we intend to collect, use, and/or share a child’s personal information. Please note that, at all times, parents should update their personal information to provide us current e-mail addresses. We will apply material changes in our Children’s Privacy Policy only in conformance with applicable law, including any applicable provisions of COPPA that require parental consent.
  
• F. Who do guests contact with questions or concerns about our Children’s Privacy Policy?
  If you need further assistance, please send an e-mail with your questions or comments to Screen Actors Guild 5757 Wilshire Blvd. Los Angeles, CA 90036-3600, ATTENTION: Legal Department/Website Children’s Privacy Policy Facsimile: (323) 549-6624 e-mail: privacy@sag.org You may also telephone us at (800) 724-0767. (If you are not 18 years of age or older, you must have your parent or guardian's permission to call this number.)

CONSENT OF PARENT OR LEGAL GUARDIAN

Certain features of the Screen Actors Guild (the "Guild") web site require the collection, use and disclosure of personally identifiable information. An example is our new iActor feature, an on line casting site which permits our members to post their resumes which will be searchable by casting directors, directors and others seeking to hire talent.

As you may be aware, state and federal law require the Guild to implement certain protections prior to granting children access to interactive functions of the iActor website. As part of those protections, we are required to obtain "verifiable parental consent" to the child's use of the website. In accordance with those protections, Guild policy is to lock children under the age of 13 out of the portions of our Site that permit the collection or submission of personally identifiable data until we receive your written consent. If your child is 13 or over but under 18 years of age, our policy is to provide him or her with provisional access for thirty (30) days at which time access will be suspended until such time as your child provides us with your written consent.

Accordingly, read the Parent Consent form for the full children's privacy policy, general privacy policy and terms of use for the Site. Please read these documents and determine if you will provide your consent to your child's participation in the Site. If you have any questions, you may contact the our WebHelp department at (323) 549-6789.

The Guild also encourages parents and legal guardians to review the information on The Site under the "Resources" link especially that related to "Young Performers" and to contact the Guild if you have any concerns.

Kindly sign and date the attached consent form in the space provided and then either mail or fax it back to the Guild at the address or fax number provided. Please also include a copy of your current valid driver's license.

After the Guild receives your letter, the Guild may call you to confirm your identity and status as the parent or legal guardian of the indicated child and that you signed the letter.