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;
- 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.