![]() ![]() “Given that children merit specific protection, any information and communication, where processing is addressed to a child, should be in such a clear and plain language that the child can easily understand,” runs another. ![]() Setting out conditions applicable to consent for processing the personal data of children aged 13 or older, one section of text from the GDPR reads: “Children merit specific protection with regard to their personal data, as they may be less aware of the risks, consequences and safeguards concerned and their rights in relation to the processing of personal data.” (Facebook’s international HQ is located in Ireland, which makes the Irish DPC the lead agency for any investigation of the project.) Less aware of the risks If it turns out that European teens have been participating in the research effort Facebook could face another barrage of complaints under the bloc’s General Data Protection Regulation (GDPR) - and the prospect of substantial fines if any local agencies determine it failed to live up to consent and ‘privacy by design’ requirements baked into the bloc’s privacy regime. (We’ve asked and will update this report with any response.) And, as we reported earlier, Facebook’s research program is open to people around the world - although the company has yet to confirm whether it has any teenage participants in Europe. Under European union law there are special requirements for processing minors’ personal data. We have asked Facebook to provide us with this information,” said the DPC’s head of communications, Graham Doyle. Before we can make any assessment as to whether or not there are any data protection concerns, we will need to understand better to what extent, how and on what basis the personal data in question is being processed and used. “The Irish DPC only became aware of this story through this morning’s media reporting. The Irish Data Protection Commission (DPC) told us it’s asked Facebook to provide more information on what data is collected via the market research program, codenamed ‘Project Atlas’, so that it can determine whether there are grounds for further investigation. Facebook could face fresh scrutiny in Europe following a TechCrunch report on its use of a VPN app to monitor people’s smartphone activity - including teenagers as young as 13. ![]()
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