"Children Front and Centre: Fundamentals for a Child-Oriented Approach to Data Processing”: Report on Public Consultation

19th November 2021

In December 2020, the Data Protection Commission (“DPC”) published draft guidance entitled “Children Front and Centre: Fundamentals for a Child-Oriented Approach to Data Processing” (the “Fundamentals”). The Fundamentals were informed by the output of the two-streamed public consultation which the DPC ran during the first half of 2019, as well as by extensive legal analysis and expert input from key child rights stakeholders over the course of 2019 and 2020.

Between 18 December 2020 and 31 March 2021, the DPC ran a public consultation on the draft version of the Fundamentals to give stakeholders a final opportunity to present their views.

Following on from this consultation, the DPC has published this report in order to give an insight into the level of engagement we experienced and to provide an overview of the headline trends and themes emerging from the feedback we received from stakeholders in their submissions, as well as the DPC’s responses to this feedback.

Click here to read about what stakeholders had to say about the Fundamentals.

In total, 27 submissions were received in response to this consultation. Participating stakeholders came from a wide range of sectors, including technology and social media companies, children’s rights charities, public sector bodies and trade associations. The full list of submissions is available below:

5Rights Foundation

Association of Community and Comprehensive Schools

Age Check Certification Scheme

American Chamber of Commerce Ireland

Age Verification Providers Association


Centre for Information Policy Leadership

Common Sense

Department of Children, Equality, Disability, Integration and Youth

Department of Education

Department of Social Protection

Facebook Ireland

Future of Privacy Forum


IAB Ireland

Irish Heart Foundation


Joint Managerial Body

Liberty Seguros

Mason Hayes & Curran LLP

National Council for Curriculum and Assessment

Privacy Vaults Online, Inc.

Royal College of Surgeons Ireland

Technology Ireland

TikTok Ireland

Tusla, Child and Family Agency