The Office of the Privacy Commissioner of Canada is moving into the next phase of work to address its strategic priority on children's privacy. Commissioner Philippe Dufresne announced at the IAPP Canada Privacy Symposium 2025 that the OPC is opening an "exploratory consultation" on potentially devising a federal children's privacy code.
In a press release following Dufresne's announcement, the OPC described a potential code as means to help companies "ensure that their products and services are designed with the highest standards of privacy and data protection in mind."
Dufresne told CPS attendees the OPC recognizes the "unique sensitivities" around children's personal data and a potential code "will be aimed at creating a safer, more transparent online environment for children." He added, "We want young people to feel empowered to exercise their privacy rights and to safely explore, learn and grow without compromising their privacy or security."
The consultation is scheduled to run through 5 Aug. with results to be presented in the following months. Dufresne said specific questions will cover "the role of consent, how privacy impact assessments can address the best interest of the child, as well as best practices and no-go zones."
The OPC's motivations for examining the feasibility and appetite for a children's code are wide-ranging. It would be the latest initiative in the children's privacy prong of the office's 2024-2027 strategic plan following the completion of a consultation on age assurance in March.
Parent input
Among the lead factors for consideration of a code is Canadian children and parents themselves indicating an urgent need for enhanced children's safeguards exists. Those views are reflected in the children's privacy response contained in the OPC's recently released 2024-2025 Public Opinion Research on Privacy Issues, which Dufresne highlighted in his remarks.
"The survey found the vast majority of parents worry about their children's privacy online," Dufresne said. "Two-thirds or more (of parents) are moderately to extremely concerned, with 45% highly concerned about risks to their child from the use or misuse of their personal information."
The OPC's survey offered some segmented responses to fully understand the issues at hand, asking parents about issues related to children ages 6-12 and teens ages 13-17. Notably with views on companies' children's privacy practices, 74% of respondents have little or no trust in children's data handling and protection.
Global influence
Canada would not be the first country to enact a children's privacy code. In his CPS remarks, Dufresne hopes to "replicate" the codes adopted in Australia and the U.K. as well as similar state-level bills in the U.S.
Canada's code isn't likely to be a one-for-one match with global partners, but the exploration is a product of ongoing the international collaboration by the OPC.
The OPC led the Global Privacy Enforcement Network's 2024 sweep on deceptive design patterns, bringing together 26 global data protection authorities in a probe of 1,010 websites. The OPC is also working on an investigation into genetic testing company 23andMe with the U.K. Information Commissioner's office, which oversees enforcement of the U.K. Children's Code.
Joe Duball is the news editor for the IAPP.
