Facebook’s longstanding rules on preteens accessing the service may be changing, as we learned earlier this month that the company was mulling the possibility of letting kids under the age of 13 join the network. Of course, opening up Facebook to a younger and younger member base comes with a series of risks, and it has been reported that to help counteract those risks any preteen account would have to sport some level of parental control.

Although Facebook has yet to acknowledge that they’re even thinking about this (only that they are always in talks about “how to help parents keep their kids safe”), it hasn’t stopped various public policy groups and child advocates from voicing concern, and even outrage in some cases. We all know that the online landscape can be rather dangerous for kids, and some people feel that Facebook is simply too mature of an environment to allow a ten-year-old to operate inside it – in any capacity, guided or not.

What kinds of safeguards and settings would you need to see from Facebook in order to feel comfortable letting your preteen join the site? Let us know in the comments.

Others may argue that fighting the inevitable is worthless, and at least this way parents can help their preteens navigate the minefield. Something like 38% of kids on Facebook are actually under the official age requirement, according to some reports. Plus, Facebook has said that they are removing around 20,000 underage accounts every day.

It’s obvious that the current policy, as it stands, is flawed. And when you think about just how hard it really is to verify age online, and how easy it is to lie – it’s no wonder Facebook may be thinking about simply opening up the floodgates and leaving it to parents to work this one out.

And if they wind up doing that they need to make a few guarantees, says a coalition of thirteen consumer groups. In a letter sent to Facebook CEO Mark Zuckerberg today, these privacy watchdog groups say that above all, any preteen experience on Facebook “should be ad-free in its entirety.”

[T]he company’s business model relies, at its very core, on data collection, ad targeting, and viral marketing, and many of its practices have generated public and government privacy concerns. If Facebook opens itself up to a younger audiences, we want assurances that any space created for children under the age of 13 on the site is safe, parent-guided and controlled, and, most importantly, free of ads (including the range of practices that are routinely employed through social media marketing).

The groups also demand that Facebook links any preteen accounts with those of their parents. If the parents don’t have accounts, they say that some sort of separate login system should be present to give parents control over the account.

They also suggest granular control over any and every action taken by the child – sharing, responding to friend requests, app use, photos – you name it, it should all be controlled by the parent. Alongside this control, the group wants an educational campaign to better inform parents about the innerworkings of the site so they can make smarter decisions about their kids’ activities.

Finally, they demand that preteen accounts not be able to be made public by any means. Information should only be accessible to friends by default.

Of course, a lot of this hinges upon the Children’s Online Privacy Protection Act (COPPA), and any future changes made to it. Facebook have said that they are “mindful of COPPA,” and have even provided a formal response to it which you can check out here.

The letter was signed by the following groups:

Consumers Union, the Center for Digital Democracy, the Academy of Child and Adolescent Psychiatry, Center for Media Justice, Center for Science in the Public Interest, ChangeLab Solutions/Public Health Law & Policy, Children Now, Consumer Action, Consumer Federation of America, Consumer Watchdog, Privacy Rights Clearinghouse, Privacy Times, Public Citizen, and World Privacy Forum.

Here’s a statement I received from Facebook concerning these consumer groups’ letter:

Enforcing age restrictions on the Internet is a difficult issue, especially when many reports have shown parents want their children to access online content and services. We welcome today’s recommendations by consumer, privacy, health and child groups as we continue our dialogue with stakeholders, regulators and other policymakers about how best to help parents keep their kids safe in an evolving online environment.

It’s clear that any move to allow younger kids on Facebook is going to draw a lot of concern – as it should. But it’s obvious that simply banning under-13s in the Statement on Rights and Responsibilities isn’t working – kids are going to get it. Whether it’s allowing them to join with parental guidance, or trying to make it tougher with something like facial age recognition, it’s pretty clear that the issue will be addressed and policies modified in the near future.

Do you think that kids under the age of 13 have a place on Facebook? Considering they are going to log on despite the rules, wouldn’t it make sense for parents to shepherd them through their first social media experience? Or is 10 or 11 simply too young for Facebook – no matter how much control you take away from them? Let us know what you think in the comments.