(19 May 2015) In order to identify major privacy concerns and problems faced by children in Hong Kong, the Office of the Privacy Commissioner for Personal Data ("PCPD") commissioned the Centre for the Advancement of Social Sciences Research ("CASR") of Hong Kong Baptist University to carry out an exploratory study in October 2014. The results1 show that parents and teachers seem to have little involvement in managing children's privacy issues and little awareness about children's problems online, a situation that was probably attributable to lack of knowledge and support.
The aim of the exploratory research was to gain a better understanding of underlying opinions and motivations in relation to child privacy issues. It provides insights into the problems and helps to develop ideas for stakeholders to follow up. Focus group interviews were conducted in October last year to understand the views of parents, secondary school students and teachers of primary and secondary schools on child privacy issues. In-depth interviews were also conducted with representatives from four non-governmental organisations (NGOs) whose main focus is children.
The PCPD is especially concerned about children's privacy issues related to the use of social networking sites and other online activities. The study shows that children are now going online at a younger age than ever, and that the lack of awareness among children and their parents or guardians and teachers may pose a serious risk. Like other organisational data users, schools have to comply with the Personal Data (Privacy) Ordinance ("Ordinance"). They should develop internal codes of practice to ensure that the requirements prescribed by Ordinance are met. Just as parents teach their children basic safety rules for the physical world, they should also teach their children basic safety rules for the virtual world.
It appears that children do not have the capacity to engage with the Internet in a safe manner in all circumstances. Children's digital footprints are now taking shape from a very young age. Some parents may post photographs and videos of their children on social media sites. These digital footprints are created for children who are too young to understand or consent. Their future ability to find, reclaim or delete materials posted by others is uncertain. Children and their parents and teachers have a lack of mutual respect for privacy which may lead to friction. It can be difficult for children to respect people's rights to privacy when they feel that their right to privacy has never been respected as subjects of rights.
Schools have always kept a wide range of personal data about their students and their families which are all necessary for basic administration and instruction. On the other hand, schools are also increasingly storing electronic data associated with "connected learning", where online resources are used for academic instruction and evaluation. While schools reap the benefits of information technology, they must not lose sight of its attendant risks to privacy and data protection especially that are of children. There have been incidents in the past reflecting a lack of vigilance and adequate security measure on the part of the schools in safeguarding the personal data of their students and their parents. Schools must take all practical steps to protect the personal data they hold against unauthorised or accidental access. If there is a decision to implement surveillance such as CCTV in schools, the school administration must undertake an objective assessment process to ensure it is the right and proportionate response. The alternative use of less privacy intrusive means of collection and use of personal data should be seriously considered.
Parents have a responsibility to protect their children's privacy. They should understand and use the privacy tools on any website or mobile applications that their children use for school or at home to limit who can see their information. They must understand and explain to their children that what they post on social media could be far reaching and long lasting. Children should also be given guidance about their privacy rights and also responsibilities as "netizens" when dealing with hateful or threatening messages on the Internet.
The focus group interviews with stakeholders generated some insights which are useful in the follow up work. Some suggestions include adding sections or topics related to privacy issues and privacy protection measures to the curriculum in subjects such as information technology, and liberal studies, and in project learning activities; and strengthening communication between parents and teachers/schools to address children's privacy issues.
The PCPD has run the Student Ambassador for Privacy Protection Programme in secondary schools for five consecutive years. In 2015, 111 partner schools have organised promotional activities on their campuses.
The PCPD has developed a thematic website called "Youth Privacy Portal" (www.pcpd.org.hk/youthprivacy) which is a one-stop portal for youngsters to learn about personal data privacy and for teachers to prepare related materials. Practical tips are available for parents to instil in their children the concept of personal data protection and respect for each other's privacy (www.pcpd.org.hk/youthprivacy/en/parent_guide.html).
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1 Executive Summary of study report is available at: