11. Parental controls

If you provide parental controls, give the child age appropriate information about this. If your online service allows a parent or carer to monitor their child’s online activity or track their location, provide an obvious sign to the child when they are being monitored.

What do you mean by ‘parental controls’?

Parental controls are tools which allow parents or guardians to place limits on a child’s online activity and thereby mitigate the risks that the child might be exposed to. They include things such as setting time limits or bedtimes, restricting internet access to pre-approved sites only, and restricting in-app purchases. They can also be used to monitor a child’s online activity or to track their physical location.

Why are they important?

They are important because they can be used to support parents in protecting and promoting the best interests of their child, a role recognised by the UNCRC and discussed in the section of this code on the best interests of the child.

However they also impact on the child’s right to privacy as recognised by Article 16 of the same convention and on their rights to association, play, access to information and freedom of expression. Children who are subject to persistent parental monitoring may have a diminished sense of their own private space which may affect the development of their sense of their own identity. This is particularly the case as the child matures and their expectation of privacy increases.

Article 5(1)(a) of the GDPR requires any processing of personal data related to their use to be lawful, fair and transparent.

“5(1) Personal data shall be:

(a) processed lawfully, fairly and in a transparent manner in relation to the data subject (‘lawfulness, fairness and transparency);”

How can we make sure that we meet this standard?

Make it clear to the child if parental controls are in place and if they are being tracked or monitored

If you provide parental controls then you should provide age appropriate information so that the child knows that parental controls are in place.

If your online service allows parental monitoring or tracking of a child, you should provide age appropriate resources to explain the service to the child so that they are aware that their activity is being monitored by their parents or their location tracked. You should provide a clear and obvious sign for the child (such as a lit up icon) which lets them know when monitoring or tracking is active.

You should also provide parents with information about the child’s right to privacy under the UNCRC and resources to support age appropriate discussion between parent and child.

The following table provides some guidelines on the type of information you might wish provide and how you might provide it. They are only a starting point and you are free to develop your own, service specific, user journeys that follow the principle in the headline standard.

You should also consider any additional responsibilities you may have under the applicable equality legislation for England, Scotland, Wales and Northern
Ireland.

Age range	Recommendations
0-5 Pre-literate & early literacy	Provide audio or video materials for the child to explain that their parent is being told what they do online to help keep them safe. Provide materials for parents explaining the child’s right to privacy under the UNCRC and how their expectations about this are likely to increase as they get older. Provide a clear and obvious sign that indicates when monitoring or tracking is active.
6-9 Core primary school years	Provide audio or video materials for the child to explain that their parent is being told where they are and/or what they do online to help keep them safe. Provide materials for parents explaining the child’s right to privacy under the UNCRC and how their expectations about this are likely to increase as they get older. Provide resources to help parents explain the service to their child and discuss privacy with them. Provide a clear and obvious sign that indicates when monitoring or tracking is active.
10-12 Transition years	Provide audio or video materials for the child to explain that their parent is being told where they are and/or what they do online to help keep them safe. Provide materials for parents explaining the child’s right to privacy under the UNCRC and how their expectations about this are likely to be increasing now they are getting older. Provide resources to help parents explain the service to their child and discuss privacy with them. Provide resources suitable for the child to use independently which explain the service and discusses privacy rights. Provide a clear and obvious sign that indicates when monitoring or tracking is active.
13 -15 Early teens	Provide audio, video or written materials for the child to explain how your service works and the balance between parental and child privacy rights. Provide materials for parents explaining the child’s right to privacy under the UNCRC. Provide a clear and obvious sign that indicates when monitoring or tracking is active.
16-17 Approaching adulthood	Provide audio, video or written materials for the child to explain how your service works and the balance between parental and child privacy rights. Provide materials for parents explaining the child’s right to privacy under the UNCRC. Provide a clear and obvious sign that indicates when monitoring or tracking is active.