Privacy and Children's data

Children’s use of social media and online gaming

Published on January 30, 2019 by Taceo Limited

Unintended consequences

Media attention has focussed on investigations by data protection regulators against social media giants like Facebook and Twitter. We have also seen the hype behind online games like Fortnite (by Epic Games) which has consistently grown in popularity since its release in 2017, especially with young children.

The use of social media and online gaming continues to surge, creating unintended consequences that are displayed through children’s behaviour, attitude and wellbeing. Increasing fallouts among children of school ages appear to relate to exchanges on social media platforms, as well as competing in online games that collect player data. These fallouts between children have a natural consequence on educational sectors that are left to address impacts on children’s behaviour, attitude and wellbeing. It is unlikely that schools or educational facilities will generally be equipped to deal with the impact of social media and online gaming on children unless they develop a better understanding themselves and incorporate aspects of data privacy and data protection into their curriculum.

Picking up the pieces

The attention has been focused on companies’ data privacy compliance regime and ethical responsibility but where does parental/ guardian responsibility fit in all this? Where children sign up to the use of social media and online gaming platforms with the full knowledge and agreement of parents/ guardians it follows that the latter should better equip themselves with knowledge of privacy and security (at a minimum) and develop their own understanding of how personal data is shared, the type of interaction that occurs or that can occur and potential impacts and pitfalls associated therewith.

If parents/ guardians are not aware of what children do online, it is arguable that there is a duty of responsibility that is not being adequately addressed.

To avoid muddying the waters, there is a distinction between game playing age rating (PEGI rating) and age of consent for uses of social media and other online apps under the GDPR (information societal services). In the U.K. the age at which a child is able to, or required to give consent to the processing of their personal data online is 13.

Where children are over the age of consent for purposes of playing online games and agree to the use of their personal data by accepting privacy/ consent notices that show up on screen (even if not read), they are deemed to have the necessary capacity to understand and therefore agree to the data sharing that may take place on these platforms. However, it is not unreasonable to recognise that each child’s social development and maturity level differs thereby impacting the way in which interactions (online or offline) are understood. This suggests a disconnect between developmental aptitude of children and the broader privacy concern that legislation aims to address.

Practical Tips

1. It’s my mobile device, not yours

Check privacy settings on the child's device or phone as well as your router settings. These can allow you to apply filtering to the type of content available online.

2. How many “friends” do you have again?

Parents/ guardians will be familiar with the growing number of “friends” accumulated on social media platforms. Those 500+ friends are not really your child’s dear friends. Raise awareness about the potential risks associated with online friends.

3. Why do you need all those apps?

Educate children on apps and personal data collection e.g., location data and IP address tracking, browser viewing habits, targeted/ non-targeted ads displayed and the broader data sharing that goes on behind the scenes. Majority of social media apps and gaming apps are not designed for children so exercise caution in use.

4. Online time

Access the platforms yourselves and if necessary, sign up to the social media sites or play those online games to understand the in-app occurrences and interaction that goes on to ensure you are comfortable with these.

5. Find out more about protecting your personal data

Enhance your understanding of how personal data is processed in social media and online gaming platforms. Stay informed. Further information – there are many a number of websites that provide useful information on children’s internet safety and privacy/ personal data processing. For example,, and have dedicated pages to help navigate the challenges.

If you would like to discuss any of the above or interested in hearing more about GDPR, data protection and data privacy, contact contact us at [email protected].