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.