Control measure: There are measures or tools in place to inform children about their rights and enable them to understand and exercise them.
Risk: If it is not easy for children to exercise their rights, then there may be a breach of articles 12-22 of the UK GDPR.
Ways to meet our expectations:
- Make tools easy for children to find that help them exercise their rights and report concerns.
- Ensure tools are age appropriate, tailored to support specific rights and easy to use.
- Communicate what is happening to a complaint or request, and include ways for the child or their parent to track the progress.
- Provide information about timescales for responding to requests from children and deal with all requests within the timescales set out in article 12(3) of the UK GDPR.
- Take swift action if you receive information indicating there is an ongoing safeguarding issue.
Options to consider:
- Embed a reporting tool in the set-up process which is highlighted and provides a clear and easily identifiable icon or other access mechanism in a prominent place on the screen display.
- Tailor the tools to support each right, for example:
- a ‘download all my information’ tool to support the right of access and right to data portability; or
- a ‘stop using my information’ tool to support the rights to restrict or object to processing.