GDPR Implementation in Respect of Children’s Data and Consent

Personal data relating to children are processed for many purposes by private and public sector organizations, including the provision of online and offline services, education, social care, healthcare and personal welfare, and as part of information on family circumstances. In some cases, the processing will include special categories of personal data. CIPL recognizes that the processing of children’s personal data may be regarded as high risk in some cases and require particular levels of care. Indeed, the importance of protecting the rights of children has been highlighted by Article 24 of the EU Charter of Fundamental Rights.

In this paper we address issues raised by the processing of personal data relating to children by private sector organizations, such as service providers in the online environment, typically for activities such as social media, the use of some online games or certain IoT products, online advertising services or e-commerce sites which can be used by children, for example by the use of pre-paid debit or gift cards.

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