Fundamentals for a Child-Oriented Approach to Data Processing

Abstract

Insights derived from personal data are often described nowadays as the ‘new gold’. Hardly an organisation exists today that doesn’t have some form of web presence that tracks, traces and measures our engagement with it in order to better target us, whether for commercial or other purposes. About a quarter of Ireland’s population are children, all of whose personal data is processed every day online and offline, in educational, health, recreational and sporting, social services, and commercial contexts. It is with this in mind that the Data Protection Commission (DPC) has produced a detailed piece of guidance entitled ‘Children Front and Centre: Fundamentals for a Child-Oriented Approach to Data Processing’ (the ‘Fundamentals’) to set out the standards that all organisations should follow when collecting and processing children’s data. These ‘Fundamentals’ have been published following an extensive 3-month public consultation period on a draft version of the document that was published at the end of 2020, and careful consideration was given to all stakeholder responses when finalising this document. The core message of these Fundamentals is that the best interests of the child must always be the primary consideration in all decisions relating to the processing of their personal data. The DPC recognises that embedding this principle into services directed at, intended for, or likely to be accessed by children will require additional resourcing and will require specialists in areas such as child development, children’s rights, and child’s psychology, to name a few. However, this is the price of doing business with children. The needs and rights of children have been overlooked in the online world for too long now, and organisations which count children amongst their users must take steps to rectify this.