Is your child’s privacy protected when using apps online?

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Special Counsel

When companies develop apps that are targeted at children, you want to know that your children’s well-being and privacy at the centre of their activities. 

As a parent, you want to be absolutely sure that privacy protection is considered, especially if the app your child is using collects their personal information. There are additional requirements and precautions that developers should consider when creating new apps aimed at children.

What do developers need to do to ensure privacy protection?

On top of developers’ obligations under the Privacy Act 2020, both the Apple App Store and GooglePlay Store impose further requirements on developers to protect children’s information if they’re developing an app that will be marketed towards and used by children. 

Developers must ensure that they’re across the requirements for the app as it is being developed. These requirements include complying with the relevant privacy laws in all the countries in which the  app will be available, which can be a complex and onerous task if the app is going to be available

worldwide. While New Zealand has strong privacy protection legislation, elsewhere, such as in the European Union, the requirements are more stringent.  

It’s no longer enough to simply publish a privacy policy that says the words required by the App Stores. Developers must turn their mind to how that policy will be implemented in their business or organisation, and who will oversee its implementation to make sure they’re not simply paying lip-service to requirements they cannot, or will not, meet in practice.

What can I do to ensure an app is safe for my child?

First of all, investigate whether it is an app targeted towards children. Is the app  in the “Kids Category” of the relevant app store?  If not, it’s unlikely to have been scrutinised by the Apple App Store or the GooglePlay Store as a children’s app, and so may not comply with the store’s privacy requirements.  

This should be a red flag to seriously consider whether it’s appropriate for your child.  

If the app is in the “Kids Category”, check out what the app’s description and supporting information says about how personal information will be collected, stored, used, and disclosed.

People often say: “Oh but the privacy policy was so long, I didn’t even bother reading it since I can’t change it anyway”.  That may be true, but even if you don’t have the opportunity to change a privacy policy, you do have the opportunity to consent—or not—to the collection and use of your child’s personal information.  

If you look into how an app deals with privacy, especially protecting children’s privacy, then you can make an informed decision about whether to download it and let your child use it. 

What if I am developing an app aimed at children?

There are steps that developers must take to ensure an app targeted at children complies with applicable privacy obligations. You can see these steps here.


Disclaimer: The content of this article is general in nature and not intended as a substitute for specific professional advice on any matter and should not be relied upon for that purpose.

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