Dec 222021
 December 22, 2021  Posted by  Govt, Non-U.S., Youth & Schools

Odia Kagan of Fox Rothschild writes:

With enforcement on children’s data privacy ramping up around the world, Ireland’s Data Protection Commission has issued a detailed report on the fundamental principles of such data privacy, as well as some helpful suggestions to controllers on how to improve.

The key principles:

  1. FLOOR OF PROTECTION: Online service providers should provide a “floor” of protection for all users, unless they take a risk-based approach to verifying the age of their users.
  2. CLEAR-CUT CONSENT: When a child has given consent for their data to be processed, that consent must be freely given, specific, informed and unambiguous, and by a clear statement or affirmative action.
  3. ZERO INTERFERENCE: Ensure that the pursuit of legitimate interests do not interfere with, conflict with or negatively impact, at any level, the best interests of the child.
  4. KNOW YOUR AUDIENCE: Take steps to identify your users and ensure that services directed at/ intended for or likely to be accessed by children have child-specific data protection measures in place.
  5. INFORMATION IN EVERY INSTANCE: Children, not just their parents, are entitled to receive information about the processing of their own personal data.

Read more of the key principles and recommendations at Privacy Compliance & Data Security.

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