Last week, the Global Privacy Enforcement Network (GPEN)
released the results from their third annual Privacy Sweep.
Twenty-nine privacy enforcement authorities spread across 21
countries reviewed 1,494 websites and mobile applications (apps)
either targeted to or popular among children – the theme of
this year's sweep.
Canadian regulators participating in the international sweep
included the Office of the Privacy Commissioner of Canada (OPC),
the Office of the Information and Privacy Commissioner of Alberta
and the Office of the Information and Privacy Commissioner of
British Columbia, who focussed their review on websites and apps
based in Canada.
Among the overall findings by GPEN, 67% of the websites and apps
examined collected personal information from children, such as
names, photos, videos, audio, addresses and phone numbers.
"Too many developers are collecting particularly
sensitive personal information such as photos, videos and the
location of children, and often allowing it to be posted publicly,
when there are clearly ways to avoid it," said Privacy
Commissioner Daniel Therrien in a statement. The OPC has repeatedly
recommended in its publications and report of investigations that
the best practice is to never collect personal information from
The OPC noted that many companies are developing innovative,
creative and dynamic technological tools that balance the purpose
of the website or app while respecting privacy protection.
The Privacy Sweep also found that 51% of websites and apps
reviewed indicated they may disclose the children's personal
information to third parties. The Privacy Sweep found that 58% of
websites and apps reviewed, while purporting not to collect
personal information, redirected children to sites and apps that
did collect personal information. The redirection was via an
advertisement or a contest that sometimes appeared to be part of
the website or app.
In considering parental or some form of adult supervision or
control, only 31% of websites and apps reviewed had any protective
control in place that would limit the collection of personal
information; even less (24%) had some form of parental
The focus of privacy protection of vulnerable groups, such as
youth and children, is one of Commissioner Therrien's current
The OPC also provided recommendations for companies to consider
when collecting, using or disclosing personal information that may
involve children, including:
Avoid collecting any personal
information from children.
Instead of requiring children to
disclose their name or photo or other personal information –
for example to register with a website or app – companies
should use protective controls such as preprogrammed avatars and
usernames that children can select instead.
The goals of the GPEN Privacy Sweep include creating awareness
and encouraging compliance with privacy legislation; however, GPEN
and the OPC note that the results of the Privacy Sweep could lead
to follow-up action being taken, including outreach and
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