Why is this relevant now?

Children are among the most vulnerable participants in today’s digital ecosystem. They interact with online platforms, apps, and connected devices long before fully understanding how their personal information is collected, used, and shared. Yet, existing privacy frameworks often lack clear, enforceable standards tailored to children’s unique needs.

The OPC’s move toward a dedicated code represents a shift from broad, principle-based privacy protections to specific, context-driven safeguards that directly address:

• Age-appropriate consent models,
• Data minimization and usage restrictions,
• Advertising practices aimed at minors, and
• Educational obligations for organizations and parents alike.

This initiative signals that Canada is preparing to join jurisdictions like the UK (Age Appropriate Design Code) and California (Children’s Privacy Act) in creating targeted rules for child data protection—potentially setting a new North American benchmark.

 

Highlights from the AccessPrivacy Workshop

Over 130 privacy professionals—including Chief Privacy Officers, senior counsel, and data ethics leaders—gathered to consider how a Canadian code could reshape organizational responsibilities. Speakers included Adam Kardash, Éloïse Gratton, Joanna Fine, and Natascha Gerlach, whose insights bridged law, policy, and international best practices.

Key themes raised during the session included:

• Operational Challenges – How will organizations manage consent verification, age estimation, and parental controls in diverse digital environments?
• Balancing Protection and Innovation – Can strong privacy safeguards coexist with user experience, personalization, and emerging technologies like AI-driven content?
• Harmonization with Global Standards – How can Canada ensure interoperability with frameworks in the UK, EU, and U.S., minimizing regulatory fragmentation for companies operating across borders?

 

What We Foresee as Important Going Forward

1. A Strong Shift Toward Privacy-by-Design for Kids

Companies will need to bake child-focused safeguards into every stage of product development—not add them as afterthoughts.

2. Heightened Regulatory Scrutiny and Enforcement

A finalized code will likely lead to more rigorous monitoring of how platforms handle children’s data, especially in industries like gaming, social media, and ed-tech.

3. Increased Role for Parents and Guardians

Expect clearer parental consent mechanisms and possibly real-time data controls, empowering families to make informed choices.

4. Global Influence

A Canadian children’s privacy code may help shape international norms, given Canada’s strong position in G7 privacy collaborations and AI governance discussions.

 

Takeaway

The OPC’s consultation—and AccessPrivacy’s workshop—show that protecting children’s data is becoming a defining issue for the next era of privacy regulation. As Commissioner Philippe Dufresne and stakeholders move toward a final framework, the challenge will be striking a balance between robust safeguards and digital innovation.

Because when it comes to children, privacy isn’t just a legal obligation—it’s a social imperative.