Lessons on Children’s Privacy 

LinkedIn’s Chief Privacy Officer, and RadarFirst Board of Directors member, Kalinda Raina, joined us in a recent session of The Privacy Collective, Teachable Moments: Children’s Privacy Policies. In this session, we discussed privacy and compliance alignment to gain lessons from children’s privacy regulation and discuss how organizations can build resilient privacy policies to protect people of all ages.

COPPA and Consent

Prior to her work at LinkedIn, Kalinda helped shape the present day landscape of children’s privacy through her work developing the original draft of COPPA with Nintendo. That work continued when she developed parental consent models at Apple, which continue to inform data privacy policies around the world today. In her podcast, Raising the Digital Future, Kalinda explores topics that caregivers and parents with young children may be learning as they raise their families. 

Since 1998, when COPPA became law, the Internet has evolved into a significantly more effective data collection machine, begging the question, how has COPPA kept up with risks children face online?

One of the problems with COPPA is it was never intended to be an all encompassing children protection law.” – Kalinda Raina, LinkedIn CPO

“One of the problems with COPPA is it was never intended to be an all encompassing children protection law. Back then, worst case some advertisers might have been collecting email addresses, names, and birthdates. Which, without parents’ understanding, might have seemed like the wild west. And there was a lot of concern among parents and in D.C. as to how we manage new technology from a regulatory standpoint.”

Today CCPA is the most recent touchpoint many Americans have to parental consent laws. At its core, CCPA places the burden on parents to understand what they’re agreeing to and when, creating pressure on the FTC to evolve the law to meet modern business practices and data collection practices at the scale of organizations like Meta and TikTok as well as common data collection tactics like Pixel cookie tracking across websites that complicate consent management for parents.

A Technologists Approach to Teaching Privacy

Setting boundaries around technology can help children understand the importance of safe online behavior. Boundaries you set around your home can include how you use technology in your house, what do you do when you take a selfie and who do you share it with, and helping children understand what is appropriate for certain situations. And of course, always model behavior you want your children to observe.

For many children who were born digital natives, the conversation around technology starts with the iPhone.

“I advise that when you’re using your iPhone around your children, that you describe what you’re using it to do. It is not an extension of you, it is a tool that mom or dad is using to do something. Describe what you’re doing, how you’re interacting with it.” – Kalinda Raina, LinkedIn CPO

“I advise that when you’re using your iPhone around your children, that you describe what you’re using it to do. It is not an extension of you, it is a tool that mom or dad is using to do something. Describe what you’re doing, how you’re interacting with it. At the same time we talk about teaching agency to kids we also think about teaching them alternate methods of communication. Because the device only wants to reinforce that the device is the only way to stay connected.”

Digital natives who have grown up in the online era where online connections are a large part of their social communities and cognitive development. During COVID-19 lockdowns, many caregivers had to reconsider their attitudes toward technology to help their children stay engaged with their communities. 

Learning not to villainize technology when it’s crucial to how kids are interacting and making friends. Today, it can be hard to imagine a life for children that doesn’t include technology.

So we have to recognize that safe usage of technology means putting boundaries on it and understanding it as a contextual tool for certain interactions with our friends.

Risks and Benefits of Technology

Developing technology finds new ways to interact with our daily lives. When it comes to teaching children about privacy, today’s parents might not fully understand when and where children are exchanging data with companies. 

Take cars for instance. Modern vehicles include personalized keys that track an individual’s speed controls, volume controls, who turns the car on, and where the vehicle travels to. For parents, it can bring relief to know where you child is and to have quick information about an incident involving the vehicle.

Simultaneously, some cars are collecting information about users through the dashboard camera through monitoring and sensors that can associate activity to a specified user.

“As privacy people who are also parents, we may be a little alarmed that all this information is now being aggregated by a third party that we don’t know. At least one of the major auto companies privacy policy says, yeah, we’re gonna sell this, and we’re sell it to data brokers and anybody and we can get get money out of it.” 

For organizations that collect data and create data collection policies, the question is simple. How are you going to create data collection practices for people who will carry a digital identify for their entire life? 

As privacy leaders, we can all work to protect the data privacy rights of people of all ages.

“Why does the data need to be saved and used for any other purpose then to share with the parent? Like these are choices we within organizations as privacy advocates can help influence. It’s incredibly hard for kids to be teenagers and have freedom these days. Parents need to be careful about how much data is collected about their kids on the technologies they’re using to help track them and understand if that makes sense at all times. But I also think companies should be able to offer tools like that without putting the privacy at risk.”

As privacy leaders, we can all work to protect the data privacy rights of people of all ages.