Schools to be asked views on children’s data protection rights

Data Protection Commission to consult a range of stakeholders on codes of conduct

Schools throughout the State are to be given the opportunity to take part in a public consultation on children’s data protection rights.

The consultation launched by the Data Protection Commission on Wednesday will run until March 1st, 2019 and will have two strands – one aimed at adults and the other at children.

It will examine issues relating to the processing of children’s personal data and their rights as “data subjects” under the EU General Data Protection Regulation (GDPR).

In its consultation document, the commission said it could be “challenging” to separate out data protection and privacy issues from other issues and risks that present for children when they are active online, such as cyberbullying, online addiction, and harmful content.


“Bearing in mind the DPC’s statutory remit as the regulator and enforcer for data protection issues, this consultation will focus solely on data-protection-specific issues.”

In its consultation document, the commission said there tended to be a general misconception that children did not have the same data protection rights as adults, but that this was not the case.

“Children have all of the same rights as adults over their personal data – data about them is still their personal data and does not belong to anyone else, such as a parent or guardian,” it said.

But it said that one of the issues the EU regulation did not address was when children should be able to exercise these rights for themselves. In Ireland, for data protection purposes, a child is somebody under 18.


The DPC invites submissions from all interested parties, including, amongst others, parents, educators, organisations that represent children’s rights, child protection organisations, representative bodies for parents and educators, as well as organisations that collect and process children’s data.

The consultation document published on Wednesday is the “adult-centred stream” of the consultation, but the commission said it also wanted to give children and young people an opportunity to have their say.

Next month, it will invite all schools and Youthreach centres to participate in the consultation. A lesson plan on personal data and data protection rights will be sent to all schools and will be available on the commission’s website at the end of January.

The DPC will use the responses from both streams of the consultation to produce guidance materials, which will include guidance specifically for children and young people, as well as guidance for organisations who process the personal data of children and young people.

Following the consultation, the commission will work with industry, government and voluntary sector stakeholders and their representative bodies to encourage the drawing up of codes of conduct to promote best practices by organisations that process the personal data of children and young people.

Written submissions can be made by email to

Alternatively, they may be posted to: Children’s Consultation, Data Protection Commission, 21 Fitzwilliam Square, Dublin 2.