Control measure: There are appropriate measures in place to provide transparency to children around the use of their geolocation data.
Risk: If there is no transparency about the use of geolocation data, this may breach article 5 (1) (a-c) (f) and 12 and 13 of the UK GDPR.
Ways to meet our expectations:
- Provide children with information, at the point of sign-up, and each time the service is accessed to:
- alert them to the use of geolocation data; and
- prompt them to discuss this with a trusted adult, if they don’t understand what it means.
- Provide children with a clear indication of when their location is and isn’t being tracked (eg by use of a clear symbol visible to the child). This ensures location tracking can’t be turned on, or left on, inadvertently or by mistake.
Options to consider:
- Provide information or explanations using graphics or visual content to support accessibility.
- Provide prompts or informative messages explaining to children the risks when changing their geolocation settings.
Control measure: Where geolocation tracking is necessary, there is an assessment to determine at what level of granularity a child's location needs to be tracked to provide each element of the service.
Risk: Without considering which elements of the service require the use and tracking of geolocation data, and then implementing privacy settings around this, there is a risk this may breach UK GDPR article 5(1)(f), the code, and the Privacy and Electronic Communications Regulations (PECR).
Ways to meet our expectations:
- Assess whether geolocation tracking is essential to provide children with your service.
- Offer children different settings for different levels of service, if appropriate.
- Apply high privacy settings to any geolocation services that go over and above the core service.
- Switch ‘off by default’ any geolocation data collection settings. Ensure children have to actively change the default setting to allow their geolocation data to be used.
- Apply a privacy setting to any option that makes the child’s location visible to others.
- Ensure you meet PECR requirements, if the geolocation data you are processing also meets the definition of location data in PECR.
Options to consider:
- Review how functionality works without granular geolocation, to avoid incentivising children to enable geolocation tracking in order to access better functionality or content.
Control measure: There are appropriate measures in place for the security and integrity of children's geolocation data.
Risk: If appropriate privacy measures are not in place to protect this information, this may breach article 5 (1) (f) of the UK GDPR.
Ways to meet our expectations:
- Apply appropriate access controls to any location data for children. Ensure access is on a ‘need to know’ level only.
- Protect any location data that you share or transfer on. Document your decision to share or transfer this information and get it authorised at senior level. Inform children of the transfer or sharing of their information.
- Implement security measures to protect location data at rest (eg encryption).
- Ensure you do not repurpose location data beyond the reason the collected it.
- Redact or anonymise location data, wherever possible.
Options to consider:
- Scramble or hash geolocation data stored in servers and back-ups, or do not retain geolocation data at all.
- Restrict children from sharing their geolocation to other people using your online service.
- Avoid displaying ‘last location’ on user profiles in your online service.