Even service providers operating at the Internet have to keep children´s right in mind, especially under new GDPR legislation. UNICEF issued highly useful discussion paper on children’s rights and business in a digital world titled “Privacy, Protection of Personal Information and Reputation Rights” (hereinafter referred to as the “Paper”).

The Paper notices that business companies should consider the effect of their privacy and data policy on the children´s digital rights in the context of their civic engagement and their life choices. Consequently, it highlights the techniques of encryption and anonymization that are also important possibilities of technical and organisational measures under GDPR. Generally, when preparing a privacy policy that includes personal data of children, the controller – the provider of the services needs to take into consideration the full range of specific children rights that may differ from the adults’ privacy rights both in scope and application. Regarding this, it is recommended to discussing such issues with the privacy legal experts from the point of aspects of decisional privacy, informational privacy and physical privacy.

If you are interested in more information about your obligations regarding the children´s personal data protection, please do not hesitate to contact us.