Developers Alliance Submits Comments to the United States Federal Trade Commission on Facial Age Estimation Technology

Facial age estimation has the potential to be a safe, secure, and equitable avenue to protect minors online. The Developers Alliance supports innovations like these and encourages the Federal Trade Commission (FTC) to nurture their growth through sandboxing and experimentation. 

Washington, D.C. September 8, 2023 – The Developers Alliance has released the following statement addressing the Federal Trade Commission’s request for public comment concerning the proposed parental consent method submitted by the Entertainment Software Rating Board, Yoti Ltd. and Yoti (USA) Inc., and SuperAwesome Ltd. 

Key Facts

  • Developers understand that in order to innovate and grow their businesses they must ensure that consumers’ privacy is protected. And no privacy or security is more valued by developers than that of minors. 
  • Facial age estimation is not facial recognition. Facial age estimation is the practice of analyzing the geometry of a person’s face to confirm they are indeed an adult. Facial age estimation converts a live facial image into numbers, comparing this data with a training data set associated with known ages. 
  • Facial age estimation can be safer, more secure, and more equitable than current age verification models. 

The following quote can be attributed to Geoffrey Lane, Head of U.S. Policy for the Developers Alliance:

“Developers work hard to earn and keep their users’ trust, and that’s why we support the responsible deployment of facial age estimation technology. The technology has the potential  to be more effective than current age verification models like credit cards, addresses, social security numbers, or birthdates. We urge the FTC to work with developers to nurture this nascent technology through sandboxing and experimentation to collect performance data and demonstrate effectiveness.”

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About The Developers Alliance

The Developers Alliance is the world’s leading advocate for software developers and the companies invested in their success. Alliance members include industry leaders in consumer, enterprise, industrial, and emerging software development, and a global network of more than 75,000 developers.

Press Contact
Heather Coull
Head of Marketing and Communications
617-688-0440
heather@developersalliance.org

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By Geoff Lane

Policy Counsel & Head of US Policy Geoff Lane serves as the Developer Alliance’s head of U.S. policy. In this role he oversees the organization’s federal legislative and regulatory agenda as well as state-level efforts. Prior to joining the Developers Alliance in 2022, Geoff worked with senior Democratic leadership in the House of Representatives. Since his time on Capitol Hill, he has held senior roles at various technology trade associations (including a previous stint at the Developers Alliance). At each stop he led efforts at the intersection of innovation and policy. He has worked on critical policy issues including privacy, encryption, patent reform, workforce development, corporate tax, tax nexus, and research and development. Geoff holds a B.A. from Miami University in Oxford, Ohio. When he is not working, you can find him booing all of his favorite Philadelphia sports teams. Geoff is based in Washington, D.C.

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