Trends and Highlights from Stream 1 of the DPC’s Public Consultation on Children’s Data Protection Rights

From December 2018 to May 2019, the Data Protection Commission (‘DPC’) ran a public consultation on the processing of children’s personal data and the rights of children as data subjects under the General Data Protection Regulation (GDPR). This consultation was launched in an effort to address a number of questions arising in the context of new child-related provisions under the GDPR, which is the first EU data protection law to highlight the importance of the protection of children’s personal data and the position of children as data subjects. This consultation was organised into two streams: one aimed at engaging adult stakeholders and industry, and the other aimed at children and young people.

Stream I sought to involve adult stakeholders in the debate. The DPC invited all interested parties – including, parents, educators, children’s rights organisations, child protection organisations, representative bodies for parents and educators, as well as organisations that collect and process children’s data – to submit their responses to any or all of the 16 questions set out in the dedicated consultation document.

The DPC has created a preliminary report on Stream I of the consultation 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 stakeholders in their submissions.

Click here to read about what adult stakeholders had to say about children’s data protection rights.

In total, 30 submissions were received in response to this stream of the consultation. Participating stakeholders came from a wide range of sectors, including technology and social media companies, children’s rights charities, public sector bodies, academia and trade associations. The full list of submissions is available below: 

• The Teaching Council
• AllOne Corporate Solutions
• Scouting Ireland
• Barnardos
• Minister for Justice and Equality
• SuperAwesome
• Church of Ireland
• Irish Society for the Prevention of Cruelty to Children
• The Pokémon Company International
• The Irish Play Therapy Association
• A group of academics
• The Ombudsman for Children's Office
• ProPrivacy Ltd.
• The Irish Wheelchair Association
• The Irish Heart Foundation
• National Council for Curriculum and Assessment (NCCA)
• Joint Managerial Body
• Department of Education and Skills
• Google
• Department of Public Expenditure and Reform
• TUSLA Child & Family Agency
• Three Ireland
• Early Childhood Ireland
• Technology Ireland
• CyberSafe Ireland
• The Software & Information Industry Association (SIIA)
• Facebook Ireland
• Castlebridge
• Snap Inc.
• Microsoft