The Digital Frontier: Safeguarding Children’s Data in an Evolving Landscape

Many thanks to our sponsor Esdebe who helped us prepare this research report.

Abstract

The pervasive integration of digital technologies into daily life has fundamentally reshaped the landscape of children’s data collection, processing, and utilisation. This transformation has precipitated a surge in critical concerns regarding privacy, security, and the profound ethical implications for minors. This comprehensive research report undertakes an in-depth examination of the multifaceted dimensions of children’s data protection. It meticulously analyses foundational legal frameworks, intricate ethical considerations, emergent potential risks, and a suite of practical, multi-stakeholder strategies designed to safeguard children’s personal information. By critically synthesising extant scholarly literature, regulatory guidance, and contemporary industry practices, this report endeavours to furnish a holistic and nuanced understanding of the formidable challenges and innovative solutions imperative for protecting children’s data in the relentlessly advancing digital epoch.

Many thanks to our sponsor Esdebe who helped us prepare this research report.

1. Introduction

The dawn of the 21st century has been inextricably linked with the proliferation of digital technologies, embedding themselves deeply into the fabric of everyday existence. For children, this digital integration begins at increasingly younger ages, spanning educational tools, entertainment platforms, social interactions, and even smart toys and wearables. This unprecedented immersion has concurrently facilitated an expansive, often unseen, collection and dissemination of personal information pertaining to minors. This phenomenon, while offering myriad benefits in terms of learning, connection, and development, has simultaneously ushered in a complex array of challenges in ensuring the fundamental privacy and robust security of children’s data (Responsible Data for Children, n.d.).

The sheer volume and granularity of data collected from children—ranging from their online behaviours, preferences, and geographical locations to biometric information and even emotional states via sophisticated algorithms—raise profound questions about their autonomy and long-term well-being. The ethical ramifications of such extensive data collection are significant, touching upon issues of informed consent, developmental appropriateness, and the potential for manipulative design. Moreover, the inherent vulnerability of children, coupled with the immense commercial value of their data for targeted advertising, behavioural profiling, and future market predictions, introduces a heightened risk of exploitation. The irreversible nature of data, once it enters the digital sphere, further exacerbates concerns about the enduring consequences of data misuse, including identity fraud, reputational damage, and algorithmic bias that could shape future opportunities (Adams, Fu, & Weng, 2023).

Addressing these complex issues necessitates a meticulous and exhaustive examination of the existing and emerging legal frameworks designed to govern children’s data. It also demands a thorough interrogation of the ethical principles that should underpin all interactions with minors in the digital realm, extending beyond mere compliance to a proactive commitment to children’s best interests. Furthermore, a critical assessment of the potential risks, which continue to evolve with technological advancements, is paramount. Finally, the development and implementation of practical, collaborative strategies involving parents, educators, policymakers, and technology developers are crucial for fostering a digital environment that is not only innovative but also safe, secure, and respectful of children’s inherent rights.

This report, therefore, aims to provide a comprehensive and detailed understanding of the challenges and solutions associated with protecting children’s data. It seeks to illuminate the intricate interplay between technological progress, legal mandates, ethical imperatives, and practical safeguards, ultimately advocating for a multi-stakeholder approach to establish a robust framework for child data protection in the contemporary digital landscape.

Many thanks to our sponsor Esdebe who helped us prepare this research report.

2. Legal Frameworks for Children’s Data Protection

The fragmented yet increasingly interconnected global legal landscape for data protection reflects varying jurisdictional approaches to safeguarding personal information, with specific provisions often carved out for children due to their unique vulnerabilities. These frameworks represent crucial attempts to establish accountability and delineate responsibilities in an environment where data flows freely across borders.

2.1 General Data Protection Regulation (GDPR)

Implemented across the European Union and European Economic Area in May 2018, the General Data Protection Regulation (GDPR) stands as a landmark achievement in global data protection legislation. Its extraterritorial scope means it applies to organisations processing the personal data of individuals residing in the EU, regardless of the organisation’s location, making it a pivotal instrument in protecting children’s data worldwide. The GDPR’s comprehensive nature includes several provisions specifically designed to enhance the protection of children’s data, recognising their diminished capacity to provide informed consent and understand the implications of data processing.

Central to children’s data protection under GDPR is Article 8, which addresses the conditions applicable to a child’s consent in relation to information society services. It stipulates that where an information society service is offered directly to a child, the processing of their personal data is lawful only if consent is given or authorised by the holder of parental responsibility over the child, especially for children under the age of 16. Member States retain the flexibility to lower this age threshold, but not below 13 years. This provision critically underscores the necessity of obtaining verifiable parental consent before processing children’s data when it relies on consent as its legal basis. The GDPR, however, does not prescribe specific methods for verifiable parental consent, instead requiring organisations to make ‘reasonable efforts’ to verify. This has led to a variety of implementations, from more robust methods like credit card verification or signed forms to less stringent ones like email confirmations, all evaluated based on the state of the art and cost (Restackio, n.d.).

Beyond Article 8, several other GDPR principles and articles are highly pertinent. Article 5 outlines the core principles of data processing, including lawfulness, fairness, and transparency, which mandate that data collection from children must be undertaken with their best interests at heart and in a manner comprehensible to them or their guardians. Data minimisation (collecting only what is necessary), purpose limitation (using data only for specified, explicit purposes), and accuracy are equally vital to prevent excessive or inappropriate data use. The principle of accountability further places the onus on data controllers to demonstrate compliance with these principles. Furthermore, Article 6, concerning the lawfulness of processing, provides six legal bases. While consent is key for children, organisations must carefully assess if other bases, such as legitimate interest, are appropriate, especially given the higher bar for children’s data. The European Data Protection Board (EDPB) has issued guidance emphasising caution when relying on legitimate interests for processing children’s data, highlighting the power imbalance between children and data processors.

Article 25, Data Protection by Design and Default, is particularly impactful. It requires organisations to implement appropriate technical and organisational measures, such as pseudonymisation, from the outset of system design to ensure data protection. This ‘privacy by design’ approach is crucial for children’s services, embedding safeguards directly into the architecture of digital products and services. Similarly, Article 35 mandates Data Protection Impact Assessments (DPIAs) for processing activities likely to result in a high risk to individuals’ rights and freedoms, a requirement almost certainly triggered when processing children’s data on a large scale or using new technologies. This proactive risk assessment helps identify and mitigate potential harms before data processing begins. Moreover, the GDPR grants individuals, including children, significant rights: the right to be informed, the right of access, the right to rectification, the right to erasure (‘right to be forgotten’), the right to restrict processing, the right to data portability, and the right to object to processing. These rights empower parents and, where appropriate, children themselves, to control their digital footprint.

2.2 Children’s Online Privacy Protection Act (COPPA)

In the United States, the Children’s Online Privacy Protection Act (COPPA), enacted in 1998 and subsequently updated, serves as the primary federal law governing the online collection of personal information from children under the age of 13. Enforced by the Federal Trade Commission (FTC), COPPA specifically targets operators of commercial websites and online services that are either ‘directed to children’ or have ‘actual knowledge’ that they are collecting personal information from children under 13 (Law Librarianship, n.d.). The Act’s focus is to give parents control over what information is collected from their children online.

COPPA imposes several stringent requirements on covered entities. First, operators must post a clear, comprehensive, and conspicuous privacy policy that details what information they collect from children, how they use and share that information, and how parents can exercise their rights regarding their children’s data. Second, and most critically, operators must obtain verifiable parental consent before collecting, using, or disclosing any personal information from children under 13. The FTC provides various methods for obtaining verifiable consent, which range in stringency depending on the type of information collected and its intended use. More robust methods, such as requiring a signed consent form by postal mail or fax, using a credit card or other online payment system that provides notification of each transaction to the account holder, or a toll-free telephone call to trained personnel, are typically required for disclosing personal information to third parties. Less stringent methods, like email plus an additional confirmatory step, may suffice for internal uses of data. Third, parents must be granted the ability to review the personal information collected from their child, revoke consent, and request the deletion of their child’s information, as well as prohibit any further collection or use of the child’s information.

Defining what constitutes a service ‘directed to children’ involves considering various factors, including the subject matter of the site, visual content, use of animated characters, music, advertisements on the site, age of models, and the presence of child celebrities. This broad interpretation ensures that platforms inadvertently attracting children are also held accountable. COPPA’s limitations primarily lie in its age threshold (under 13) and its focus on commercial operators, meaning that platforms not explicitly targeting children, but frequently used by them (e.g., general social media sites), might fall outside its direct purview unless they have actual knowledge of collecting data from under-13s. Despite these limitations, COPPA has served as a foundational model for child online privacy legislation globally, demonstrating a commitment to parental oversight and child protection in the digital realm.

2.3 Other International Regulations and Legislative Trends

Beyond the foundational frameworks of the GDPR and COPPA, numerous other countries and jurisdictions have developed or are in the process of developing their own regulations to protect children’s data, often reflecting local cultural norms, technological advancements, and specific vulnerabilities. This legislative patchwork creates a complex compliance landscape for global digital service providers.

In the United Kingdom, the Data Protection Act 2018 complements the GDPR by incorporating its provisions into national law and includes specific measures for children’s data protection, such as clarifying the digital age of consent at 13. Furthermore, the UK Information Commissioner’s Office (ICO) has published an ‘Age Appropriate Design Code’ (Children’s Code), which provides a set of 15 standards that online services must meet to protect children’s privacy. While not a law itself, adherence to the Code significantly reduces the likelihood of breaching GDPR or DPA 2018 provisions. The Children’s Code mandates that online services likely to be accessed by children should be designed with their best interests as a primary consideration, and ensure privacy settings are high by default, data minimisation is practiced, and profiling is restricted.

Australia’s Privacy Act 1988, while not containing specific provisions for children’s consent comparable to GDPR or COPPA, relies on the concept of ‘capacity’ to consent. This means that consent can be given by a child if they have the maturity to understand the nature of the decision. For younger children or those lacking capacity, parental consent is required. The Act also includes the Notifiable Data Breaches scheme, which requires organisations to notify individuals and the Australian Information Commissioner when their personal data is involved in a data breach likely to cause serious harm, implicitly extending this protection to children’s data. Several states in Australia are also exploring their own children’s online safety legislation.

In the United States, beyond COPPA, the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA), represents a significant state-level initiative. The CCPA grants consumers various rights over their personal information, including the right to know, delete, and opt-out of the sale or sharing of their data. Importantly, for consumers under 16, their data cannot be sold without affirmative opt-in consent (or parental consent for those under 13), establishing a higher standard of protection than for adults. Other states are also enacting similar privacy laws, creating a mosaic of state-specific regulations.

Globally, countries like Brazil with the Lei Geral de Proteção de Dados Pessoais (LGPD) have drawn inspiration from the GDPR, including specific references to children’s and adolescents’ data, requiring parental or guardian consent. Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA) also requires consent for the collection, use, and disclosure of personal information, and generally assumes that children under 13 lack the capacity to provide meaningful consent, thus requiring parental consent. India’s proposed Digital Personal Data Protection Bill, while under development, is expected to include specific provisions for processing children’s data.

These diverse regulations underscore a growing global consensus on the need for enhanced data protection for children, yet highlight the ongoing challenge of harmonising standards and ensuring consistent enforcement across different jurisdictions. The underlying principle in many of these frameworks, implicitly or explicitly, is the recognition of the child’s evolving capacity and the paramount importance of their best interests.

Many thanks to our sponsor Esdebe who helped us prepare this research report.

3. Ethical Considerations in Children’s Data Collection

Beyond the strictures of legal compliance, the collection and processing of children’s data necessitate a profound engagement with ethical principles. These considerations move beyond mere adherence to regulations, delving into the moral imperative to ensure that children’s well-being, autonomy, and developmental needs are prioritised. The unique vulnerability of children requires a heightened ethical sensitivity, acknowledging that their cognitive abilities, understanding of consequences, and agency differ significantly from adults.

3.1 Informed Consent and Assent

Obtaining genuinely informed consent from parents or legal guardians is a foundational ethical requirement in any context involving the collection of children’s data. This consent must be freely given, specific, informed, and unambiguous, meaning parents must clearly understand what data is being collected, why, how it will be used, with whom it will be shared, and for how long it will be retained. Crucially, the information provided to parents must be presented in clear, concise, and accessible language, devoid of legal jargon or obscure technical terms, to enable truly informed decision-making. The challenge, however, lies in the complexity of modern data ecosystems, where data often flows through multiple third parties, making it difficult for even digitally literate parents to fully comprehend the implications of their consent.

However, ethical frameworks extend beyond parental consent to incorporate the critical concept of ‘assent’ from the child (Robinson, 2024; Cambridge Prisms: Precision Medicine, n.d.). Assent acknowledges the child’s evolving capacities and their developing ability to form independent judgments. It involves providing children with age-appropriate information about data collection activities, allowing them to understand what is happening and ensuring they agree to participate. This practice respects the child’s autonomy, affirming their right to have a say in matters affecting them, even if their legal capacity for consent is not yet fully mature. For younger children, assent might involve simple verbal agreement and a demonstration of understanding, whereas for older children or adolescents, it may be a more formal process akin to adult consent, tailored to their cognitive and emotional development.

Challenges in obtaining assent include adapting communication strategies to various age groups and developmental stages. For instance, explaining data privacy to a five-year-old playing a game requires a very different approach than explaining it to a 14-year-old using a social media platform. Furthermore, the dynamic nature of consent for children means that assent given at one stage may need to be re-evaluated as the child grows and their understanding evolves. Ethical guidelines often suggest that children should be given the opportunity to withdraw their assent at any time, even if parental consent remains in place, reinforcing their developing agency. This continuous dialogue and respect for a child’s evolving perspective are central to an ethically robust data collection practice.

3.2 Beneficence and Non-Maleficence

The principles of beneficence (doing good) and non-maleficence (avoiding harm) are cornerstones of ethical research and data collection, particularly when involving vulnerable populations like children (WHO SMART Trust, n.d.). Organisations and researchers collecting data from children are ethically bound to ensure that such activities unequivocally serve the best interests of the child and do not expose them to unnecessary or undue risks. This imperative extends beyond simply avoiding overt harm to actively seeking to maximise potential benefits while rigorously minimising potential harms.

From a beneficence perspective, data collection should genuinely contribute to positive outcomes for children. This could include improving the efficacy of educational tools through personalised learning analytics, enhancing health interventions through monitoring and data-driven insights, or fostering social-emotional development through well-designed digital platforms. The benefits must be tangible, proportionate to the data collected, and clearly articulated. There is an ethical obligation to ensure that the stated benefits are not merely a pretext for commercial data exploitation.

Conversely, non-maleficence demands a vigilant assessment and mitigation of all potential harms. This encompasses a broad spectrum of risks, including psychological distress or discomfort arising from intrusive data collection, the potential for manipulation through persuasive design tailored by data analytics, or the long-term impact of a digital footprint on future opportunities and identity formation. Data collection practices must minimise the risk of children encountering inappropriate content, falling victim to cyberbullying, or being exposed to predatory behaviours online. Furthermore, the ethical obligation to avoid harm extends to preventing the use of children’s data for discriminatory profiling, which could limit their access to future services, educational opportunities, or financial products.

Ethical data practices, therefore, require a proactive and continuous risk assessment process, not just at the design stage but throughout the data lifecycle. This includes implementing robust security measures to prevent data breaches, employing stringent anonymisation or pseudonymisation techniques where appropriate, and establishing clear data retention policies that prevent data from being held indefinitely. The ‘best interests of the child’ principle, enshrined in Article 3 of the UN Convention on the Rights of the Child (UNCRC), serves as an overarching ethical guide, compelling all stakeholders to consider the holistic impact of data practices on children’s present and future well-being (Legal Lens, n.d.).

3.3 Privacy and Confidentiality

Maintaining privacy and confidentiality is paramount in the ethical collection and processing of children’s data, reflecting fundamental human rights and specific protections afforded to minors. While often used interchangeably, privacy refers to an individual’s right to control their personal information, determining what data is collected, by whom, and for what purposes. Confidentiality, on the other hand, pertains to the obligation to protect information that has been shared or collected, preventing unauthorised access, use, or disclosure.

Ethical guidelines strongly emphasise the necessity of securely storing and handling children’s personal information to prevent any unauthorised access or disclosure that could lead to harm. This commitment necessitates the implementation of robust technical and organisational data protection measures. Technologically, this involves employing state-of-the-art encryption for data both in transit and at rest, rendering it unreadable to unauthorised parties. Pseudonymisation and anonymisation techniques, which either replace identifiable information with artificial identifiers or irreversibly strip identifying attributes, are crucial, particularly when data is used for research or aggregated analysis, to minimise the link to individual children. Access controls must be rigorously applied, ensuring that only authorised personnel with a legitimate need can access sensitive child data, and their activities should be logged and audited.

Beyond technical measures, organisational policies and practices are equally vital. This includes comprehensive staff training on data protection principles and procedures, clear internal protocols for data handling, and strict adherence to legal requirements such as the GDPR’s provisions on data security and breach notification. In the event of a data breach, ethical practice demands prompt notification to affected individuals and regulatory authorities, alongside transparent communication about the measures being taken to mitigate harm. Data minimisation is a key ethical principle here: collecting only the data that is strictly necessary for the stated purpose significantly reduces the potential impact of any breach or misuse.

Moreover, the ethical imperative for privacy and confidentiality extends to how children’s data is shared with third parties. Organisations have a responsibility to scrutinise the data protection practices of any partners, vendors, or sub-processors, ensuring that contractual agreements enforce equivalent or stronger privacy standards. The commercial ecosystem around children’s data, often involving advertising networks, data brokers, and analytics firms, presents complex challenges to maintaining confidentiality. Ethical practice dictates a transparent and restrictive approach to third-party data sharing, always prioritising the child’s privacy over commercial interests. Ultimately, upholding privacy and confidentiality is not merely a legal obligation but a profound ethical commitment to preserving the dignity, safety, and future well-being of children in the digital world.

Many thanks to our sponsor Esdebe who helped us prepare this research report.

4. Risks Associated with Children’s Data

The extensive collection and processing of children’s data, while offering potential benefits, simultaneously introduces a spectrum of significant and evolving risks. These risks are amplified by children’s inherent vulnerability, their developing understanding of digital interactions, and the permanence and widespread dissemination capabilities of online information. Understanding these hazards is crucial for developing effective preventative and mitigative strategies.

4.1 Identity Theft and Exploitation

The collection and storage of children’s personal data present a particularly insidious risk: identity theft. Unlike adults, whose credit histories and financial activities are routinely monitored, children’s identities are often ‘clean slates,’ making them prime targets for malicious actors. Fraudsters can leverage stolen birth certificates, social security numbers, medical records, or other personal identifiers to open credit accounts, obtain government benefits, apply for loans, or even commit crimes under a child’s name. These fraudulent activities can go undetected for years, often only surfacing when the child reaches adulthood and attempts to apply for a student loan, a job, or credit, leading to severe financial distress, ruined credit scores, and complex legal battles (Jiao et al., 2025).

Beyond identity theft, children’s data is susceptible to various forms of exploitation. Commercial exploitation is rampant, where highly granular data—such as online search history, app usage, game preferences, and even emotional responses captured by smart devices—is used to build detailed psychological profiles. These profiles enable highly targeted advertising, often promoting products or services that children are developmentally ill-equipped to resist, potentially leading to manipulative or predatory marketing practices. This exploitation can extend to influencing purchasing decisions within families, creating brand loyalties, and even shaping consumer behaviour for decades to come, all without genuine informed consent.

Furthermore, children’s data can be exploited for social engineering, where personal information (e.g., school name, pet’s name, hobbies derived from online profiles) is used by groomers or predators to establish trust and manipulate children. The irreversible nature of data once it is online exacerbates these risks; information, once disseminated, can be cached, copied, and shared widely and persistently, making it nearly impossible to fully delete or control its spread. This ‘digital permanence’ means that even seemingly innocuous data collected in childhood can have unforeseen, long-term consequences, impacting a child’s reputation, future opportunities, and overall well-being. The rise of interconnected devices, from smart toys to educational platforms, creates ever more data points, expanding the attack surface for identity theft and the scope for commercial and social exploitation.

4.2 Exposure to Inappropriate Content

Children’s increasing engagement with online platforms and digital content inherently exposes them to the risk of encountering material that is inappropriate, harmful, or disturbing. Despite the implementation of content filtering mechanisms and age-gating technologies, children may inadvertently or purposefully bypass these safeguards, accessing content that is violent, sexually explicit, hate-filled, or promotes self-harm, radicalisation, or dangerous challenges. The sheer volume and dynamic nature of online content, coupled with the rapid evolution of communication channels (e.g., encrypted messaging, obscure social platforms), make comprehensive content moderation an intractable challenge.

The psychological and emotional impacts of exposure to such content can be profound and long-lasting. Children may experience anxiety, fear, confusion, desensitisation to violence, body image issues, or internalise harmful messages. For instance, exposure to extreme violence can normalise aggression, while sexually explicit content can distort understanding of healthy relationships. Misinformation and disinformation, increasingly prevalent online, can also be profoundly damaging, shaping children’s worldviews and potentially exposing them to harmful ideologies or health risks. Algorithmic amplification, where content (even harmful content) that generates high engagement is promoted, further compounds this risk, pushing extreme narratives into children’s feeds.

Even with sophisticated content restrictions, technological limitations and the ingenuity of malicious actors allow some harmful content to bypass filters. Children can encounter inappropriate material through peer-to-peer sharing, embedded links on seemingly innocuous sites, or through ‘dark corners’ of the internet that are not easily indexed or monitored. The ubiquitous nature of internet access across various devices means that exposure can occur in private spaces, limiting adult oversight. The cumulative effect of repeated exposure to harmful content can be detrimental to a child’s emotional development, mental health, and overall sense of security, underscoring the urgent need for a multi-layered approach to content safety.

4.3 Cyberbullying and Online Harassment

The anonymity and perceived distance afforded by the internet can embolden aggressors, leading to pervasive and insidious forms of online harassment known as cyberbullying. This phenomenon presents a significant and growing risk for children, with profound and often long-lasting psychological and emotional consequences. Cyberbullying manifests in various forms, including: denigration (spreading false or cruel information), impersonation (pretending to be someone else to damage their reputation), outing (sharing private information without consent), trickery (luring someone into revealing secrets), harassment (repeated offensive messages), and cyberstalking (intense and repeated harassment).

Unlike traditional bullying, cyberbullying is often 24/7, reaching victims in their homes and private spaces, providing no respite. The content can be widely disseminated to a vast online audience, amplifying the humiliation and making it difficult to escape. The permanence of online content means that embarrassing photos, videos, or messages can resurface years later. Victims of cyberbullying often experience intense feelings of isolation, shame, helplessness, and fear. This can lead to severe mental health issues such as depression, anxiety, social withdrawal, loss of self-esteem, academic decline, and, in tragic cases, self-harm or suicide. The pervasive nature of online interactions means that children can be exposed to bullying behaviours across diverse platforms, from social media and gaming environments to educational forums and private messaging apps.

Collected data can inadvertently or directly contribute to cyberbullying. For example, location data can be used to track or identify a child, while shared personal information (e.g., interests, friends, photos) can provide ammunition for bullies. The rapid pace of online communication and the viral nature of content sharing make it challenging for parents, educators, and even platforms to intervene effectively or promptly. The emotional burden on child victims is immense, as they grapple with constant fear of new attacks, reputational damage, and a feeling of being trapped in a relentlessly hostile online environment. Addressing cyberbullying requires not only robust reporting mechanisms and platform accountability but also fostering digital literacy and empathy among children, empowering them to recognise and respond to online harassment safely and effectively.

4.4 Emerging and Systemic Risks

Beyond the well-established risks, the rapid evolution of digital technologies introduces new and systemic threats to children’s data and well-being:

• Algorithmic Bias and Discrimination: Data collected from children, particularly in educational technology (EdTech) or predictive analytics, can inadvertently or intentionally be used to build profiles that lead to biased or discriminatory outcomes. Algorithms trained on biased datasets might, for instance, limit a child’s access to certain educational resources, recommend specific career paths based on inferred socioeconomic status, or even identify children from specific demographic groups as ‘at risk’ based on flawed correlations. These biases, if embedded early, can perpetuate or exacerbate existing societal inequalities, shaping a child’s opportunities and life trajectory without their awareness or ability to challenge it (Ethical Data Initiative, 2024).

• Psychological Manipulation and Addiction: Many digital services and games designed for children leverage sophisticated psychological principles and persuasive design elements (e.g., reward systems, endless scrolls, push notifications) to maximise engagement and screen time. While often framed as benign, these ‘dark patterns’ can exploit children’s developing cognitive control and emotional vulnerabilities, leading to addictive behaviours, sleep deprivation, impacts on attention span, and feelings of inadequacy if they do not achieve certain digital milestones. Data collected on their preferences and behaviours allows companies to fine-tune these manipulative techniques, blurring the line between engaging entertainment and engineered dependency (Responsible Data for Children, n.d.).

• Loss of Privacy and Surveillance: The increasing deployment of Internet of Things (IoT) devices, smart toys, wearables, and biometric technologies (e.g., facial recognition, voice recognition) in children’s environments leads to unprecedented levels of pervasive surveillance. These devices often continuously collect sensitive data – location, conversations, movements, physiological responses – which can be aggregated to create highly detailed profiles of a child’s daily life. This constant monitoring, often without explicit and informed consent, normalises surveillance from a young age, potentially eroding children’s understanding of privacy and their expectation of personal space. The long-term implications for future freedoms and societal norms, where personal data is consistently collected and analysed, are profound.

• Data Breaches and Secondary Harms: While identity theft is a direct consequence, data breaches involving children’s personal information can lead to a cascade of secondary harms. Beyond financial fraud, the exposure of sensitive medical information, educational records, or even private communications can cause immense emotional distress, reputational damage, and social stigma. For example, a breach of a school database could expose a child’s special educational needs, disciplinary records, or family circumstances, leading to bullying or discrimination.

• Impact on Developmental Trajectories and Autonomy: The pervasive datafication of childhood can profoundly influence a child’s developmental trajectory. Constant algorithmic recommendations might narrow their exposure to diverse ideas or experiences. The awareness of being constantly monitored or profiled might inhibit risk-taking or exploration, crucial for identity formation. The commercialisation of their data, often without their understanding, can undermine their developing sense of autonomy and control over their own lives. This shift from ‘childhood by design’ to ‘childhood by data’ fundamentally alters the context in which children grow and develop.

These emerging and systemic risks underscore the need for a more proactive, rights-based approach to children’s data protection, one that anticipates future harms and prioritises children’s long-term well-being over immediate technological convenience or commercial gain.

Many thanks to our sponsor Esdebe who helped us prepare this research report.

5. Practical Strategies for Protecting Children’s Data

Effectively safeguarding children’s data in the dynamic digital age necessitates a comprehensive, multi-stakeholder approach that extends beyond regulatory compliance to embrace proactive ethical responsibility and collaborative action. No single entity can unilaterally address the breadth of challenges; rather, concerted efforts from parents, educational institutions, technology companies, governments, and civil society are indispensable.

5.1 Role of Parents and Guardians

Parents and guardians are the primary guardians of their children’s well-being and play an unequivocally crucial role in navigating the complexities of the digital world. Their involvement is multifaceted, encompassing monitoring, education, and advocacy.

Firstly, fostering open communication is paramount. Creating a safe and non-judgmental environment where children feel comfortable discussing their online experiences, concerns, and encounters is more effective than relying solely on surveillance. Regular conversations about what they are doing online, who they are interacting with, and what content they are consuming help build trust and provide opportunities for guidance. This extends to discussing the concept of data, privacy, and the implications of sharing personal information.

Secondly, enhancing parental digital literacy is essential. Parents need to be equipped with the knowledge to understand the privacy policies and terms of service of the platforms and apps their children use. Regularly reviewing and adjusting privacy settings on devices, social media, gaming platforms, and educational applications can significantly mitigate risks. Understanding how data is collected, used, and shared by various services, including those integrated into smart toys and IoT devices, empowers parents to make informed decisions about what technologies to introduce into their children’s lives. This includes vigilance about the information children are encouraged to share online by schools or extracurricular activities, ensuring explicit consent is always sought and understood.

Thirdly, implementing and teaching responsible use of parental control tools can be highly effective. These tools, which can manage screen time, filter inappropriate content, and monitor online activity, should be used judiciously and as part of a broader educational strategy, rather than solely for surveillance. Explaining the purpose of these tools to children and involving them in setting boundaries can foster a sense of shared responsibility and respect, promoting digital citizenship rather than resentment. Educating children about online safety, critical thinking regarding online content, identifying potential scams or predatory behaviour, and understanding the permanence of their digital footprint are foundational skills.

Finally, parents can act as advocates. Engaging with schools, technology companies, and policymakers to demand stronger data protection standards, more transparent practices, and child-centric design principles contributes to a safer digital ecosystem for all children. This involves participating in community discussions, providing feedback to service providers, and supporting legislative efforts aimed at enhancing child privacy.

5.2 Educational Institutions’ Responsibilities

Educational institutions, by virtue of their central role in children’s development and their increasing reliance on digital learning tools (EdTech), bear significant responsibilities for protecting student data. Their role extends beyond classroom instruction to creating a secure and privacy-respecting digital environment.

Firstly, schools must implement robust data governance policies and practices. This includes strict data security measures for all student records, whether digital or physical, encompassing secure storage, access controls, encryption, and regular security audits. Crucially, schools must establish clear data breach response plans, ensuring prompt notification to affected families and regulatory bodies in the event of an incident. Staff training on data protection principles, privacy laws (e.g., GDPR, COPPA, FERPA in the US), and best practices for handling sensitive student information is mandatory and ongoing.

Secondly, schools have a profound responsibility to scrutinise and vet EdTech vendors and service providers. Before adopting any digital tool, schools must conduct thorough due diligence regarding the vendor’s data collection, use, sharing, and security practices. This involves reviewing privacy policies, understanding data minimisation commitments, and negotiating strong data protection clauses in contracts that prohibit the commercial exploitation of student data. Schools must ensure that vendors comply with all relevant child data protection laws and commit to not building profiles on students for non-educational purposes (Restackio, n.d.).

Thirdly, integrating comprehensive digital literacy and citizenship curricula is vital. Beyond technical skills, students need to be taught critical thinking, media literacy, responsible online behaviour, and the importance of protecting personal information. This education should address topics such as understanding privacy settings, identifying misinformation, recognising cyberbullying, and knowing how to report online dangers. Fostering a school culture that prioritises digital safety and respectful online interactions is crucial.

Finally, schools must establish transparent reporting mechanisms for addressing online threats or violations of data rights. Students and parents should know whom to contact and how to report concerns about privacy breaches, cyberbullying, or inappropriate content encountered within school-provided digital environments. Schools also have a role in educating students about their data rights, empowering them to understand and exercise these rights appropriately.

5.3 Role of Technology Companies

Technology companies and service providers that develop products, platforms, or services accessible by children hold a profound ethical and legal responsibility to prioritise child data protection. Their actions directly shape the digital environment children inhabit.

Firstly, implementing ‘Data Protection by Design and by Default’ (as per GDPR Article 25) is paramount. This means embedding privacy and security safeguards into the core architecture of products and services from the initial design phase, rather than as an afterthought. This includes using data minimisation principles (collecting only essential data), pseudonymisation, robust encryption, and building systems with privacy-enhancing technologies. Privacy settings should be set to the highest possible level by default, requiring users to actively opt-out of greater data sharing, rather than opting-in.

Secondly, designing for age-appropriateness and child-centricity is critical. User interfaces, privacy policies, and terms of service must be comprehensible to the intended child audience or their parents. This involves using clear, concise language, visual aids, and age-appropriate consent mechanisms. For very young children, services should aim to collect minimal or no personal data, and assume parental consent is required. Robust age verification mechanisms, while challenging, are increasingly necessary to segment users and apply appropriate protections, though these must be implemented in a privacy-preserving manner.

Thirdly, prohibiting the commercial exploitation of children’s data for targeted advertising and profiling is an ethical imperative. Technology companies should actively disengage from business models that rely on monetising children’s data for non-essential services. Where advertising is present, it should be contextual and non-targeted, ensuring children are not exposed to manipulative or developmentally inappropriate marketing. Transparent data practices, including clear statements about data retention and deletion policies, are essential for building trust.

Fourthly, investing in sophisticated security infrastructure and incident response capabilities is non-negotiable. This includes continuous vulnerability assessments, penetration testing, and dedicated incident response teams capable of swiftly identifying and mitigating data breaches. Companies must also actively monitor for and remove inappropriate or harmful content, employing both technological solutions (AI/ML) and human moderation, with clear reporting pathways for users.

Finally, responsible AI development is crucial (Jiao et al., 2025). As AI becomes more integrated into children’s apps and devices, companies must ensure that AI systems are fair, transparent, and do not exploit children’s vulnerabilities. This involves auditing AI models for bias, ensuring explainability where possible, and preventing the use of AI for manipulative profiling or surveillance of children. Collaboration with child development experts and child rights organisations can help guide the ethical development and deployment of new technologies.

5.4 Role of Government, Regulatory Bodies, and Civil Society

Beyond individual stakeholders, systemic change requires robust action from governmental, regulatory, and civil society entities.

Government and Regulatory Bodies play a pivotal role in establishing, enforcing, and continually updating the legal frameworks for children’s data protection. This involves:

• Enforcement: Actively investigating and prosecuting violations of child data protection laws, issuing substantial penalties, and demonstrating a commitment to accountability.
• Guidance and Interpretation: Providing clear, actionable guidance to businesses, educators, and parents on how to comply with complex regulations, especially as new technologies emerge. This includes issuing codes of practice (like the UK’s Children’s Code) and best practice recommendations.
• Policy Evolution: Continuously reviewing and updating legislation to keep pace with rapid technological advancements (e.g., AI, Metaverse, Web3) and emerging risks. This may involve cross-border collaborations to address the global nature of data flows.
• Public Awareness Campaigns: Educating the public, particularly parents and children, about online risks, data privacy rights, and safe digital practices.
• Funding Research: Supporting independent research into the impact of digital technologies on children’s development, privacy, and well-being.

Civil Society Organizations and Researchers contribute significantly through advocacy, research, and resource development:

• Advocacy: Championing children’s rights in the digital space, lobbying for stronger legislative protections, and holding technology companies and governments accountable.
• Research: Conducting independent studies on children’s digital experiences, the impact of data collection, and the effectiveness of current protection mechanisms, thereby informing policy and practice.
• Resource Development: Creating educational materials, tools, and best practice guides for parents, educators, and even children themselves, to enhance digital literacy and promote safer online environments.
• Monitoring and Reporting: Acting as independent watchdogs, monitoring compliance, identifying emerging threats, and reporting on data privacy issues affecting children.

This interconnected ecosystem of responsibility ensures that children’s data protection is not merely a reactive compliance exercise but a proactive, ethical commitment embedded across all levels of the digital landscape.

Many thanks to our sponsor Esdebe who helped us prepare this research report.

6. Conclusion

Protecting children’s data in the digital age is an increasingly complex and urgent imperative, demanding a multifaceted and dynamically adaptive approach. The extensive integration of digital technologies into children’s lives, from educational tools to entertainment and social platforms, necessitates a comprehensive framework encompassing robust legal compliance, profound ethical considerations, and collaborative practical strategies. While foundational regulations such as the GDPR and COPPA provide critical legal protections, the relentless pace of technological innovation, particularly with the advent of artificial intelligence and immersive digital environments, requires ongoing vigilance and continuous adaptation of these safeguards.

This report has meticulously explored the intricacies of existing legal frameworks, highlighting their strengths in mandating verifiable parental consent and establishing data protection principles, while also acknowledging the challenges of global harmonisation and keeping pace with technological shifts. It has delved into the ethical bedrock of children’s data collection, emphasising the paramount importance of informed consent and assent, the principles of beneficence and non-maleficence, and the inviolable right to privacy and confidentiality. These ethical considerations extend beyond mere legal checkboxes, urging stakeholders to prioritise the child’s best interests and long-term well-being above commercial gain or technological convenience.

The examination of risks has illuminated a spectrum of harms, from traditional concerns like identity theft, exposure to inappropriate content, and cyberbullying, to emerging systemic threats such as algorithmic bias, psychological manipulation, pervasive surveillance, and the potential erosion of childhood autonomy. These risks underscore the profound and often irreversible consequences of inadequate data protection, necessitating proactive and preventative measures.

Crucially, the report has outlined a comprehensive array of practical strategies, underscoring the indispensable roles of various stakeholders. Parents and guardians are central to fostering digital literacy, open communication, and responsible use of technology within the family unit. Educational institutions bear the responsibility of implementing robust data governance, vetting EdTech tools, and integrating comprehensive digital citizenship curricula. Technology companies must commit to ‘privacy by design,’ age-appropriate development, responsible AI practices, and a fundamental shift away from business models that exploit children’s data. Furthermore, governmental bodies, regulatory authorities, and civil society organisations are vital for establishing strong legal frameworks, ensuring stringent enforcement, providing clear guidance, and advocating for children’s digital rights.

Ultimately, creating a truly rights-respecting digital future for children requires an enduring commitment to collaboration. It demands ongoing dialogue, shared responsibility, and a collective determination to place children’s privacy, security, and developmental well-being at the forefront of every technological innovation and policy decision. By upholding these principles, we can aspire to build a digital environment where children can explore, learn, and grow safely, fostering their potential without compromising their fundamental rights and future.

Many thanks to our sponsor Esdebe who helped us prepare this research report.

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