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Europe Data Protection Digest | Notes from the IAPP Europe Managing Director, April 1, 2016 Related reading: A conversation on protecting children's privacy



Greetings from Brussels!

In the technological race to be all the digital society promises, it is important we bear in mind the "e-exposure" of our younger citizens and ensure they receive appropriate guidance and protection in the face of the digital onslaught. It is a brave new world in many respects, and while the Internet is a wonderful and catalytic medium, there remains a fundamental and continuous need for raising awareness to the risks one may encounter. Technology is fast becoming an influential driver in areas of children's creativity, communication and learning simultaneously. Many parents – myself included – are overwhelmed by the speed with which social media apps, games, mobiles and tablets are becoming central to children's lives. Not only do we have the everyday duty of care, now we must also be mindful of the potential harm to impressionable minds in the cyber world.

Among many educational initiatives being endorsed across Europe, there is one particular initiative I think merits additional attention. No one can doubt that a significant contribution to safety online stems from the actions industry can take, in cooperation with public bodies. In late December 2015, the UK Council for Child Internet Safety published a Practical Guide for Providers of Social Media and Interactive Services. UKCCIS is a group of over 200 organizations from across government, industry, law, academia and charity sectors, working together in partnership to help keep children safe online.

The guide was created voluntarily by UKCCIS members, including participation from Facebook, Twitter, Google and It contains practical advice for social media players, interactive service start ups, as well as medium-sized companies and has been designed to help organizations ingrain online child safety into their Web or mobile business. Digital brands can certainly benefit from the guidance in implementing the basics of safety policies and procedures straight off the drawing board: "safety by design.” One of the goals is to instill a confidence that can be assured to both users and parents that abiding organizations are managing safety risks in a responsible fashion. Furthermore, from a business perspective this can only benefit sponsors, advertisers and investors who in turn need to consider their own reputational risks by association.

The guide references six safety principles, one of which is Privacy & Controls:

  • Limit the user information you collect, share, use and publish.
  • Tell users what information you collect, why and how long you’ll keep it.
  • Give users the ability to see what personal information you hold about them.
  • Offer privacy settings options, including "privacy-by-default," to give control to your users.
  • If you collect or use personal information about a child or young person, consider requesting consent from their parent or guardian.
  • Offer privacy tools to all your users, especially to children and young people and their guardians, and make sure they all know about them.
  • Get legal and expert advice to develop your privacy policy and practices on managing data you collect, use, share and retain.

Annie Mullins, OBE director of Trust & Safety at Europe, who was involved in creation of the guide said, “It will be an important resource for companies to see what good practice looks like as more apps and interactive services are used by children and young people.”

The guide was developed in consultation with the U.K. government, and the U.K. Information Commissioner’s Office. Moreover, the guide’s working committee was chaired by the U.K. communications regulator Ofcom, who have a seat on the UKCCIS board. I can only commend both regulators for their active involvement. Overall, this is a very welcome initiative and, despite the U.K. focus, the practical advice will certainly be helpful for start ups and companies operating under other jurisdictions.

If you are a privacy pro working in the digital field, the guide is definitely worth your time.


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