Protecting Children's Data: What Really Matters

Children's personal data calls for a higher standard of care than ordinary commercial data. Under most privacy frameworks, including the UN Convention on the Rights of the Child, a child is anyone under 18, although legal thresholds vary between jurisdictions. The GDPR recognizes that children merit specific protection because they may be less aware of the risks involved in the processing of their personal data.

Digital learning platforms and education services often process more than basic identifiers such as names, student IDs, and dates of birth. They may also hold confidential information such as academic results. Even where this data is not legally classified as sensitive, it carries extra ethical and reputational weight because it concerns children.

Three principles matter most when safeguarding children's data.

1. Collect Only What Is Necessary

The most effective protection is not collecting unnecessary data in the first place. Every additional data point creates additional risk. If information is not essential for delivering the service, verifying identity, or meeting legal obligations, it should not be collected.

Each data field should be questioned:

• Is a full date of birth required, or would an age range be enough?
• Do demographic details need to be retained once the service has been delivered?

Limiting collection to what is genuinely needed reduces both the compliance burden and security exposure, in line with the data minimization principle in GDPR Article 5(1)(c). It also builds trust with parents, schools, and regulators.

2. Hold People and Partners to High Standards

Children's data protection depends not only on systems, but also on the people and vendors handling the data.

• Vet third-party providers. Cloud platforms, software vendors, and analytics tools should meet recognized information security standards, such as ISO/IEC 27001, which demonstrate independently audited security controls.
• Restrict internal access. Only qualified personnel should access children's data, and permissions should follow the principle of least privilege.
• Train staff regularly. Employees handling student records should receive ongoing privacy training.
• Consider background checks for individuals working directly with children's personal information.

These measures support the security of processing obligations under GDPR Article 32.

3. Balance Regulation, Technology, and Transparency

Organizations processing children's data are frequently accountable to education ministries, schools, and public authorities, all of which expect clear oversight of how student data is handled.

At the same time, AI-driven tools and learning analytics are reshaping education. They can improve efficiency, but they also introduce risks such as excessive profiling and unnecessary expansion of data collection. Where AI is used to process children's data, systems should remain proportionate, explainable, and subject to human oversight, consistent with the OECD AI Principles.

Because these technologies affect minors, transparency towards parents and guardians is essential. Families should be able to understand:

• what data is collected,
• how it is used,
• who can access it, and
• whether automated systems influence outcomes.

Clear privacy notices and open communication support the GDPR's transparency principle under Article 5(1)(a).

Key Takeaways

Children's data deserves greater care because it belongs to a more vulnerable group. In practice, this means:

• collecting only the data that is necessary,
• ensuring that staff and partners meet strong security standards, and
• being transparent with regulators, schools, and families.