Protecting children’s online privacy; priorities from the ICO

In an era defined by the value of personal data and the critical importance of data privacy, safeguarding children’s online privacy has emerged as a pressing concern. The Information Commissioner’s Office (ICO) is now calling on social media and video-sharing platforms for enhanced data protection measures, particularly focusing on children. Since the Children’s code of practice in 2021, substantial progress has been achieved in promoting online safety for children. However, as we advance into 2024, there remains significant work ahead to ensure the digital rights of children are adequately protected.

Priorities for 2024-2025

The ICO’s recent announcement of its priorities for the coming year underscores the importance of prioritizing children’s privacy online. Central to this agenda is the recognition of the critical role of consent in data management, particularly concerning how children’s personal information is collected, used, and shared online.

Default privacy and geolocation settings

One of the key areas of focus is the implementation of default privacy and geolocation settings. The ability to track the location data of a child poses significant risks, including compromising their physical safety and mental well-being. It is essential that children’s profiles are private and geolocation settings are turned off by default. Platforms can mitigate these potential harms and prioritize the protection of children’s privacy.

Profiling Children for Targeted Advertisements

Another concern highlighted by the ICO is the practice of profiling children for targeted advertisements. Children may not be fully aware that their personal information is being collected and used to tailor the adverts they see. This lack of transparency can impact children’s autonomy and control over their personal information, potentially leading to financial harm (i.e. encouraging in-service purchases) and exposure to inappropriate content. Unless there is a compelling reason to use profiling for targeted advertising, the ICO advocates for it to be turned off by default.

Using children’s information in recommender systems

The design of recommender systems poses yet another challenge to children’s privacy online. Algorithms that generate content feeds based on children’s behavioral profiles and search results can inadvertently lead them to harmful content. These systems may also incentivize children to spend more time on platforms, increasing their exposure to potential risks. Addressing these issues requires a careful balance between providing personalized experiences and protecting children’s privacy.

Consent for children under 13 years old

Crucially, the ICO emphasizes the importance of obtaining proper consent, especially for children under the age of 13 who are legally unable to consent to the use of their personal information. Platforms must think about how they are gaining consent, what age assurance technologies they are using, and applying appropriate protections for children. All of this is vital to mitigating potential harm.

International cooperation and collaboration

Recognizing that children’s privacy is a global concern, the ICO is committed to collaborating with international regulators and online services to raise data protection standards worldwide. By sharing expertise and best practices, we can work towards creating a safer online environment for children.

As we navigate the complexities of the digital age, it is imperative that we prioritize the protection of children’s online privacy. By implementing robust consent mechanisms, enhancing default privacy settings, and fostering international cooperation, we can ensure that children are safer and more secure in their online interactions.

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