CIPL’s response draws on our extensive work on accountability, age assurance, and responsible data use, and makes several key points, including:
- The need for a holistic, multistakeholder approach to children’s online safety — one in which industry provides safe and well-designed services, regulators set outcome-driven standards, parents and caregivers are equipped with the tools and literacy to guide their children’s digital lives, educators deliver digital literacy as a core competency, and children themselves are empowered and resilient online.
- Recognition that children’s digital participation brings genuine benefits — for learning, development, accessibility, and social connection — and that effective regulation should protect children without foreclosing access to age-appropriate content and services.
- A strong preference for risk-based and proportionate approaches over categorical bans, supported by context-specific risk taxonomies tailored to individual business models and operational realities.
- The need for proportionate, privacy-preserving age-assurance measures that balance child protection with established privacy rights, minimise data collection, mitigate exclusion risks, and safeguard personal data.
- The view that the age of consent should only be changed where clear evidence demonstrates a significant benefit to children’s well-being, given the compliance burdens and risks of fragmented protections.
CIPL is committed to supporting child safety and the ability of children to thrive online as mutually reinforcing goals.