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It seems to be TikTok should be castigated for the first two mistakes (allowing children on their platform, and implementing the birth date dialog poorly.) However their response to that second error seems sane to me. If they're going to reactivate accounts closed for being too young, shouldn't they make an attempt to verify the age of the person reopening the account? I doubt the FTC would be amused if TikTok started permitting 12 year olds to reopen their accounts with no form of attempted verification.

Also I'm not quite sure I buy the argument that the birth date dialog was bugged. Defaulting it to the current date is dumb, but was it really non-functional for some users? Really? Or did some users just click past it unthinking, annoyed that they were being asked something without bothering to stop and look at what they were being asked? The later seems more likely to me. These users would doubtlessly be annoyed, but what really can be done about that scenario? Those users should take it as a learning experience and be thankful TikTok is a thoroughly frivolous platform so they lost nothing of worth this time.

If it's possible to click through a form with all defaults retained, you should assume that some users will do so. It's probably also safe to assume that deleting their account and all of their uploaded content is not the typical user expected behavior from doing so.

I don't think the problem was defaulting to the current date. No default is probably better in general for this sort of thing, and in hindsight it definitely would have been better in this case. But for a field for which you really need the user to provide a value, if you're going to set a default, that default should be obviously and universally invalid (the current date qualifies for that when you're asking for DOB), and you should have logic in place to deal with obviously invalid inputs.

Sure. But even if they did that form right, they'd still have some adults flip the year a few years, some falling short of 13. At that point they get banned because that's what the FTC requires, so what procedure do you use to let them appeal? Asking for an ID seems reasonable to me.

I agree that the appeals decision is a little bit tricky and that asking for an ID is probably the best option in those cases. But I'd bet that some very basic, sensible validation would have reduced the number of those cases by orders of magnitude.

You could ask for a CC or something like that, which wouldn't be bulletproof but probably reasonably good enough. But I think you'd still have the EFF complaining that not everybody has a credit card, particularly teenagers, just like they object to the photo ID requirement.

Asking for a photo ID was probably easier for them than asking for a credit car though, since with the credit card method they now have to worry about PCI compliance. Getting themselves out of one regulatory shithouse by walking into another probably wasn't something they were eager to do.

They could ask the appealing user to upload a quick video of themselves requesting the appeal, and then use common sense to grant the appeal to people who reasonably appeared to be adults. That might make the FTC upset with them a second time though, since you'd doubtlessly have kids filming and uploading appeal videos, which would probably put TikTok back in violation of COPPA...

I don't think asking for a link to other social media like facebook would help, because even though Facebook is presumably in compliance with COPPA, somebody having an account on Facebook and being in compliance with COPPA doesn't necessarily mean they are >13 years old; their parent or legal guardian could have given them permission to use facebook, but not tiktok. So you can't assume that control of a facebook account means they're >13 or have parental approval to use your service.

There might be other ways out of this mess, but I can't think of any at the moment.

> was it really non-functional for some users? Really?

What matters is the result, not some technicality like whether the form worked correctly in every browser.

And the result was bad. No users were actually zero days old but they got their videos deleted just the same.

When you get bad results, don't blame the user for not understanding your system. It's always a bad design.

See also: Boeing 737 Max

What's the minimum age do you think? You've got toddlers running around with ipads. I know they use youtube, they might be using tiktok as well.

TikTok assumed that what my daughter entered was correct. The birth date she saved made her 5 months old.

> These users would doubtlessly be annoyed, but what really can be done about that scenario?

Easy--never create an input field where clicking through on the default value is guaranteed to do something the user doesn't want, irreversibly. That's terrible design.

That doesn't really solve the problem, only reduces the magnitude of it. You'd still have 30 year olds entering something like 2010 as their birth date just because they're impatient, didn't care to provide their real birth date, and didn't realize the significance of the question.

They'd go from "wtf stop asking me questions" to "you don't need to know that about me" to "wtf I'm locked out?" in about 5 seconds flat. And I don't think there is anything you can do about that. If they implemented a second chance system ("are you sure about that? input a different year or we're going to lock your account") it sounds like that would be another violation of COPPA, defeating the point of the whole ordeal.

Of course good design won't solve every single user problem, but it will solve a lot of them, and we have a responsibility to do that.

> Also I'm not quite sure I buy the argument that the birth date dialog was bugged

Sorry to break it to you, but this happened to my daughter. Defaulted to 2018, she saved quickly (assuming her birth year was the default) without noticing.

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