On March 25th, 2015 the Privacy Commissioner of Canada issued a News Release and key tips for websites which are aimed at children to follow in order to protect privacy. The tips include the following:
- Don't collect children's personal information unless you absolutely need it and be careful about inadvertent collection of personal information – for example, via the creation of user names.
- Make sure that younger users are able to understand the privacy information you provide – or that they understand the need to involve an adult in making decisions.
- Make clear who needs to agree to terms and conditions; children should not be expected to "agree" to legalistic language.
The tips were issued in conjunction with a report of the Commissioner's investigation into the Webkinz.com website, a website aimed at children ages 6 to 13, which is reported to have an estimated 800,000 users. In addition to the full report, the Commissioner has published a Backgrounder on the investigation which sets out the key findings. As a result of that investigation, the Commissioner made some 11 recommendations. The key ones are summarized in the Backgrounder as follows:
- Avoid the collection of children's personal information wherever possible;
- Be careful about the "inadvertent" collection of personal information;
- Consider the target audience of the website service and use age-appropriate language, and interactive and innovative techniques to communicate with them;
- Ensure that children understand the importance of involving a parent or guardian in certain processes, e.g., in accepting a website's terms and conditions;
- Monitor the practices of third-parties communicating and interacting with users;
- Inform users of the actual privacy practices of the website and explain what practices apply to which website, if more than one site is covered by a user agreement or privacy policy; and
- Provide privacy information in the language(s) in which the website is offered.
The full report of the investigation is available on the Commissioner's website.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
