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AI and Children’s Privacy and Consent

Privacy | Oct 24, 2023

CSA Group Childrens privacy - AI and Children's Privacy and Consent

Today, children are growing up surrounded by Artificial Intelligence (AI), from interactive toys and virtual assistants to educational software and video games.  AI is 'everywhere all at once' and reshaping their experiences, raising critical questions about its impact on their right to privacy.

The Pervasiveness of AI in Children's Lives

  • AI technologies are deeply integrated into children's lives, providing recommendations on what to watch, read, listen to, and even whom to befriend. However, the extent of AI’s presence varies, with some applications being more visible than others.
  • For instance, interactive toys like Mattel’s Hello Barbie utilize voice recognition and algorithmic data collection, while educational settings employ AI-based anti-plagiarism software and evaluation tools.  While these technologies offer convenience and personalized experiences, they also raise critical questions about children's right to privacy.

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  • The lack of transparency and oversight in these decision-making processes further exacerbates the risks. Children are particularly vulnerable as they may not fully comprehend the implications of their online interactions.
  • AI systems, driven by vast amounts of data, make decisions that can significantly impact children's lives, both in the present and future.

Rethinking Consent Mechanisms

  • The existing consent framework falls short in tackling AI-related privacy challenges impacting children, with Canadian policies primarily centered on adult privacy rights, neglecting children's unique needs.
  • Since minors lack the legal capacity to give consent, this duty shifts to parents, a situation complicated by the intricate nature of AI systems and the far-reaching consequences of data collection.
  • This necessitates a critical reevaluation of our approach to obtaining and handling consent in the context of children's interactions with AI.

Privacy by Design is Critical

  • This approach entails embedding privacy safeguards into the products from the outset, minimizing the data collected, and ensuring that children's needs are prioritized. Manufacturers, many of whom may not have expertise in software design or cybersecurity, would benefit from best practices and guidance in this area.

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  • Addressing the privacy risks associated with AI requires a collaborative effort. Policymakers, industry leaders, children's advocates, and the children themselves must come together to develop and implement effective solutions. The creation of advisory panels and the conduct of collaborative workshops, as done by CSA Group, are steps in the right direction.

Recommendations for a Safer Digital Future

  • Targeted actions are required to address the gaps in policies and solutions related to AI and children’s digital privacy.
  • Privacy by Design: Intervening during the design phase of AI-based technologies can restrict unnecessary data collection and embed governance measures.
  • Support for All Stakeholders: Parents, children, policymakers, regulators, and manufacturers all need support and guidance to navigate the complexities of AI and privacy.
  • Engagement and Collaboration: Creating an advisory panel comprising children's advocates, researchers, and industry experts can provide diverse perspectives and drive constructive solutions.

See:  ChatGPT Faces Investigation by Canadian Privacy Commissioner

  • Strategic Interventions: Addressing AI-related children's privacy risks requires interventions from design and technology adoption to monitoring and accountability.
  • Informed Consent and Privacy Rights: The mechanism of consent is complex, especially for children. There is a need for a more nuanced understanding of children's privacy rights, separate from their parents.


As AI continues to intertwine with children's daily lives, it is imperative to address the associated privacy risks proactively. By adopting a collaborative approach, involving all stakeholders, and focusing on privacy by design, we can create a digital environment that respects and protects children's privacy rights, ensuring a safer and more secure future for the next generation.

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