GDPR: what are some things to consider when processing personal data from minors?

When processing personal data of minors (children under the age of 18), they are entitled to specific protection, as they are often less aware of their rights, the potential risks and consequences associated with the processing of their data.


Minors must be informed about which personal data are collected about them, what the data will be used for, what the risks, rules, guarantees and rights are and how they can exercise their rights with regard to the processing. It's the researcher's job to inform minors in a clear and understandable manner, using a medium that's appropriate to the minor's environment and discernment. It's important to note that minors don't lose their right to be informed if the research requires the parents'/guardian's consent. In that case, you must inform both the parents/guardian and the minor in an appropriate manner.

Legal ground

A legal ground is also required for the collection of personal data from children. This will often be consent and in some cases public interest or legitimate interest. If personal data of minors are collected and processed on the basis of consent, the researcher must obtain the consent of the person with parental responsibility.

Regardless of the legal ground, it's recommended from an ethical point of view to also ask the minors themselves for their permission or consent to participate in the study and to process their personal data.

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Last modified Aug. 28, 2023, 10:30 a.m.