The Data Protection Commissioner (DPC), along with other Data Protection Authorities across Europe, have been contacted by the European Consumer Council in relation to possible data protection issues regarding children’s toys.

The concern is centred around toys that interact with children through the use of microphones and cameras that can be connected to the internet or apps on a smartphone or tablet, which may take recordings of a child’s voice and the “conversations” between the child and toy, which can then be passed on to a third party for targeted marketing or advertising.

The DPC has urged parents to take extra care when considering the purchase of ‘electronic’ or ‘interactive’ toys for their children. The DPC has set out some useful questions for parents to consider when deciding to purchase an interactive toy for a child:

  1. Does the toy have an ability to connect to the internet or to use “Bluetooth” to connect to a smartphone or tablet?
  2. Can the toy be used with an app that is available for anyone to download and use?
  3. Has the toy got sensors to record the child’s voice or to react to a child’s voice?
  4. Has the toy got sensors that have the ability to take photographs or to record video footage?
  5. Can the sensors be switched on and off?
  6. Is it obvious when the sensors are switched on?
  7. Is it clear from the instructions if information is being transmitted to a third party? If so, are there contact details for that third party? Do the companies’ websites have privacy policies that allow you understand what they do with the information collected, how long will the data be retained and how do you request that any personal data be erased?
  8. Is it clear from the packaging that the information is being collected securely?
  9. If you have to register on a website to open an account for the toy or app, does it allow you to see what information is being collected and allow you to control it. In particular, can you stop the data being used for advertising or being shared with third parties?

The DPC has advised parents to ensure they are happy with the answers they find in relation to the above questions and if a parent is not satisfied with their findings, to perhaps reconsider purchasing the toy for the child.

The key point is to read the small print and be aware of what you are buying and signing up to.

Please click here for note of full guidance.