- Information: The provision of meaningful information to adults by service providers is sometimes very unclear and unpredictable. In this context, how can information for services aimed at children (or, worse, used by, but not aimed at children) be communicated in clear language that will enable a child to make a meaningful and informed decision?
- Withdrawing consent: Notwithstanding various legitimate reasons that would make a withdrawal of consent appropriate, how can the child, or how can an adult wishing to put youthful indiscretions behind himself or herself, exercise their right to remove personal data? This problem is infinitely more acute in the digital environment.
- Profiling: This is probably the issue that is possibly the weakest point of the whole Regulation. Instead of directly and clearly regulating the issue of generating new personal data based on profiling, the new legislation is more than a little unclear. There are, undoubtedly, useful protections, not least the right to object to such processing of data. However, profiling which would aim to manipulate tastes or commercial demands for child-related products that does not directly profile the child as actually being a child appears to slip through the cracks somewhat.
GDPR: We might not be quite finished just yet
In this article, Joe McNamee, Executive Director of European Digital Rights, an association of digital civil rights organisations from across Europe, gives his view on the progress of the General Data Protection Regulation (GDPR). He thinks that, while much has been done in the legislative phases, there is still a long way to go before it comes into force.
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