On 17 December 2021, the Irish Data Protection Commission
("DPC") published its final report (the
"Fundamentals")1 detailing
its guidance on processing children's personal data, entitled
"Children Front and Centre: Fundamentals for a
Child-Oriented Approach to Data Processing".
"The Fundamentals have immediate application and
operational effect, now forming the basis for the DPC's
approach to supervision, regulation and enforcement in the area of
processing of children's personal data."
(DPC press release, 17 December 2021)
In addition to giving 14 principles for processing
children's data, the Fundamentals contains the DPC's advice
on:
- particular obligations under the General Data Protection
Regulation ("GDPR") including legal
basis requirements under Article 6, digital age of consent
verification under Article 8 and transparency under Article 12;
and
