The UK’s independent authority set up to uphold information rights in the public interest, promoting openness by public bodies and data privacy for individuals.

Geolocation tracking concerns how online services monitor and use children’s geolocation data. This is typically data taken from a user's device which indicates the geographical location of that device. It includes GPS data and data about connection with local Wi-Fi equipment or QR codes.

The Children’s code Geolocation standard outlines expectations for online services likely to be accessed by children that monitor and process children’s geolocation data. The links below give examples and information on how geolocation impacts children’s rights under the UNCRC. We also offer code recommendations on how to positively support and mitigate risks to these rights in this context.

Article 6: Life, survival and development

Children have an inherent right to life and survival. Their physical and emotional development should not be impeded.

Geolocation tracking poses risks to this right, where sharing with other users - that is either on-by-default, not obvious to the child when in use or does not revert back to off after use – exposes children to risks of physical or emotional harm (for example through stalking, bullying or harassment). Geolocation tracking can support this right where services use it for safeguarding and parental controls (note that services must still follow the Children’s code Geolocation and Parental standards).

Article 15: Freedom of association

Children have a right to freely associate and gather with others in the real world and in the digital environment.

Geolocation tracking poses risks to this right where parental controls for tracking children’s movements are used without adequate transparency for the child.

Article 19: Protection from violence, abuse and neglect

Children have a right to be protected from all forms of physical or mental violence, abuse, maltreatment or exploitation.

Geolocation tracking poses risks to this right, where sharing with other users - that is either on-by-default, not obvious to the child when in use or does not revert back to off after use – exposes children to risks of violence or abuse (for example through stalking, bullying or harassment). Geolocation tracking can support this right where services use it for safeguarding and parental controls (note that services must still follow the Children’s code Geolocation and Parental standards).

Children’s code recommendations on geolocation:

  • Switch geolocation tracking to off-by-default, unless it is essential to the core of your service (for example, a map service).
  • Provide information at the point of sign-up, and each time a child accesses the service, that alerts them to the use of geolocation data. The service should prompt the child to discuss this with a trusted adult if they don’t understand what it means.
  • Revert settings which make the child’s location visible to others to ‘off’ after each use. This is unless you can demonstrate that you have a compelling reason to do otherwise, taking into account the best interests of the child.
  • If your service allows a parent or carer to monitor their child’s online activity or track their location, provide an obvious sign to the child (such as a lit up icon or a pop-up) when they are being monitored.
  • Provide parents with information about the child’s right to privacy under the UNCRC, which explains why children have a right to know where their online activity is being tracked.

For connected devices that track geolocation - find ways to communicate ‘just in time’ information. This explains how you are using children’s data at the point of use and avoid passive collection of geolocation data.