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Online tools for users to make complaints and requests about how you use their data

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Online tools, in the context of the Children’s code, are mechanisms to help children exercise their data rights simply and easily when they are online. The UK GDPR gives all people, including children, rights to determine if and how services use their personal data. Children have rights to access, correct, erase, restrict and object to the processing of their data. They also hold further rights relating to data portability (ie transferring data between similar services) and  automated decision-making and profiling. 

The Children’s code Online tools standard outlines expectations for online services likely to be accessed by children to provide transparent tools for children to exercise their full range of data rights. The links below give examples and information on how online tools impact children’s rights under the UNCRC. We also offer code recommendations on how to positively support and mitigate risks to these rights:

Article 5: Parental guardianship and the evolving capacities of the child

The rights and responsibilities of parents and guardians to provide appropriate support to children to exercise their rights must be respected. Services must recognise that this support changes as children grow and their capacities develop.

This right is at risk where services either do not provide online tools for children (or parents on their behalf) to exercise their data rights, or if the tools are inaccessible or untransparent. Services support this right when they provide these online tools and they meet the requirements of the Online tools standard.

Article 8: Development and preservation of identity

Children have a right to develop and preserve their identity, including:

  • nationality;
  • name;
  • family relations;
  • gender; and
  • other personal identity characteristics.

Services support this right where they provide online tools that meet the code’s requirements for children (or parents on their behalf) to correct or erase data relating to their identity. This right is at risk where services either do not provide online tools, or if they are inaccessible or not specific to these data rights (for example where children can download a copy of their data but not correct it).

Article 12: Respect for the views of the child

Children who are capable of forming their own views have rights to express them, in all matters that affect them.

This right is at risk where services do not provide online tools for children (or parents on their behalf) to exercise their data rights, or the tools are inaccessible. Services support this right  when they provide these online tools and they meet the requirements of the Online tools standard.

Article 32: Protection from economic exploitation

Children have a right to be protected from economic exploitation of all forms.

This right is at risk where services do not provide accessible online tools for children (or parents on their behalf) to exercise their right to data portability. This is the ability to access and move their relevant data to a competing service. Services support this right when they provide this online tool and it meets the requirements of the Online tools standard.

Article 42: Knowledge of rights

Children and parents have a right to be made aware of the rights they hold under the UNCRC - in this context as they apply to their data and the Children's code.

Services support this right when they provide online tools for children (or parents on their behalf) to exercise their data rights and they meet the requirements of the Online tools standard. Pro-privacy nudges that encourage children to engage with these tools can also support this right.

Children’s code recommendations on online tools:

  • Provide prominent and accessible tools to help children (and their parents where appropriate) exercise their data protection rights relating to how services use their data – including their rights to:
    • access;
    • correct;
    • erase;
    • transfer; and
    • object
  • Ensure tools for children to exercise their data rights are age-appropriate and easy for them to use.
  • Ensure tools for children to exercise their data rights are specific to the individual right they support.
  • Include ways for the child or their parent to track the progress of complaints and requests relating to their data rights.
  • Include mechanisms for children to indicate when they think complaints or request relating to data rights are urgent, and why.
  • Use pro-privacy nudges that encourage children to engage with online tools, where appropriate.

Depending on the age of the child, you should prompt them to speak to an adult before they exercise their data rights.