David Woods

+44 (0)1733 887793 dvwoods@greenwoodsgrm.co.uk

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GDPR: The Personal Data of Children

Corporate and Commercial / 06 July 2018

Research from the BBC in July 2018 concludes that children may be signing up to terms and conditions that “only university students can understand” when using apps.

The GDPR requires particular protection to be provided to children when collecting their personal data, on the basis that they may be less aware of the risks involved.

If you are relying on consent as the lawful basis for processing personal data when you offer an online service to a child you must be aware that in the UK children below the age of 13 are not able to provide their own consent.  For children below that age the consent of a person with parental responsibility for the child is required.

Privacy notices for children must be written in a way they will be able to understand.

Children have the same rights over their personal data as adults.  The right to erasure may be particularly relevant in relation to personal data provided for processing when the person was a child.

If you have questions, we can help.  Please get in touch.


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This update is for general purposes and guidance only and does not constitute legal or professional advice. You should seek legal advice before relying on its content. This update relates to the prevailing circumstances at the date of its original publication and may not have been updated to reflect subsequent developments. If you have general queries about our updates, please email: mailinglists@greenwoodsgrm.co.uk

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