In recent years, the protection of children on the Internet has become an acute issue, in relation with the growing interest of children for on-line activities, and in particular for social networks. The greater availability of personal data on networks opens the door to new risks of misuse, from commercial advertising targeting children to serious crimes such as cyber-bullying and child abuse. The numerous initiatives taken, at different levels, to raise awareness and protect children in the on-line world, are therefore very welcome.
Let us analyse briefly the main challenges from a privacy perspective, before highlighting some main actions taken by stakeholders, and in particular Data Protection Authorities, in order to enhance the protection of children.
The average age of children accessing the Internet is falling: children use the Internet ever earlier, but their capacities to make a sound judgement do not evolve as rapidly. As a consequence, they represent easy targets, vulnerable to manipulation. They may also be responsible for circulating information which might be harmful, to themselves or to others.
One of the main issues with the posting of information on the Internet is the related loss of control over that information: once it is divulged, it becomes available on search engines and can be registered and further communicated using peer to peer or other network facilities. Deleting or rectifying such information is a real challenge.
It is a challenge not only because the information becomes widely available, but also because the author may be difficult to identify. Next to the right of every individual to request the deletion of his or her information published on the Internet, there is also a right for users (including those publishing or using information) to remain anonymous on-line. These two rights, which have as a purpose to protect the privacy of individuals, may collide. Part of the solution could be found in raising awareness and enhancing the responsibility of those - including children - posting or using information on-line. In other words, prevention is better than cure.
The actions taken
It is therefore very welcome that initiatives have been developed by authorities in Member States and at European level, to raise awareness of children and also of service providers such as social network services. These initiatives have been listed and are supported by the recent Resolution adopted Prague on 29-30 April 2010 at the Spring Conference of European Data Protection and Privacy Commissioners1. In this resolution, Data Protection Authorities support the setting up of joint actions of awareness and education of youngsters at a European and International level.
A good example is Safer Internet Day2, which takes place each year in February, and which is the occasion for campaigns and competitions involving children all over the EU. Other projects deserving specific attention are those developed in Norway, including a website and a brochure specifically built to attract the attention of kids and teenagers3, the "Dadus" website of the Portuguese DPA4, the Czech DPA drawing competition, as well as its educational programme5, or the awareness programmes in which CNIL participates in France6. It is worth mentioning that many of these initiatives are developed through collaboration between data protection authorities and other national stakeholders, such as the Technology Board and the Directorate for Education and Training in Norway or the Government Directorate for Internet (DUI) in France.
This is complemented by recommendations towards the private sector: the Article 29 Working Party, composed of Data Protection Authorities of the EU, has not only adopted opinions calling for more awareness and education of young people, it has also concentrated on the role of social network services. In May 2010, the Working Party has called on private actors7 that have signed the "Safer Social Networking Principles for the EU" drafted by the Commission to pay specific attention to issues relating to minors, and notably the conditions to obtain the consent of their parents before they can engage in some activities on-line.
One of the main steps for the future will be to transform principles in effective practice. It is our wish that, as supported by the Prague Resolution, synergies between Data Protection Authorities and collaboration with private actors will continue to develop in a constructive way.
1 http://www.uoou.cz/uoou.aspx?menu=125&submenu=614&loc=733&lang=en. The resolution includes a very detailed list of official documents published on this issue, including the declaration of the Committee of Ministers of the Council of Europe of 20 February 2008 on protecting the dignity, security and privacy of children on the Internet.
3 "You decide": http://www.teknologiradet.no/FullStory.aspx?m=3&amid=4736
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