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Collection and Use of Personal Data through the Internet – Points to Note for Data Users Targeting at Children / December 2015
Collection of personal data
Avoiding (instead of just limiting) the collection of personal data
Instead of just limiting the types and amount of personal data to be collected, data users should also consider
the best practice of not collecting any personal data from children altogether, given that children may not fully
understand all the privacy risks and may not know whether they should or how to refuse providing personal data.
This is particularly relevant in relation to personal data that is more sensitive in nature, such as that related to health,
biometrics, etc.
Collection of third party’s (such as their parents’ or friends’) personal data from children (particularly younger ones
at primary school age and below) may be regarded as unfair in some circumstances.
Best Practice Tips
• Instead of showing a complex online form comprising both mandatory and optional fields, a two-part
form should be used to clearly group mandatory and optional fields separately. This will also prompt
data users to reconsider if they should avoid collecting the optional data;
• Avoid open-type questions in online forms by which children may feel more inclined to over-supply
information to data users;
• “Just in time” reminders or warning messages may be adopted in the online form to alert children of the
minimum amount of information they are expected to supply; and
• When collecting information about third parties (such as parents or friends), children should be explicitly
reminded that they need to consult and obtain consent from those people before providing their personal
data.
Offering of discussion forum
Although data users who offer discussion forums to children may believe forum contents are posted by children
voluntarily, they should still ensure that children understand the privacy implications.
Tips
• When offering discussion forums to children, data users should ensure that children know, prior to
taking part in any discussion, who else may join the forums and have access to all the discussions,
whether the forums are monitored/moderated by the data users, and whether discussions can take place
among a specific group of users, etc.; and
• Deletion and editing of posts should be offered so that children have a second and considered chance
to change their minds or alter the content after posting.