Dan Cooper, Sam Jungyun Choi, Shona O’Donovan, and Stacy Young of Covington and Burling write:
On December 18, 2020, the Irish Data Protection Commission (“DPC”) published its draft Fundamentals for a Child-Oriented Approach to Data Processing (the “Fundamentals”). The Fundamentals introduce child-specific data protection principles and measures, which are designed to protect children against data processing risks when they access services, both online and off-line. The DPC notes that all organizations collecting and processing children’s data should comply with the Fundamentals. The Fundamentals are open for public consultation until March 31, 2020.
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