Art.8 Conditions applicable to child's consent
Where consent is the lawful basis and information society services are offered directly to a child, processing the child's personal data on the child's own consent is lawful only from age 16, or from the lower age a Memb
5
artefacts
0
held by a system
3
at each review
hard
to go live
Document repository
where the evidence lives
teal = a system already holds it · olive = produced at each review
system holds itEvidence a system already holds
none for this control
periodic reviewEvidence produced at each review
- The assessment of whether the service is an information society service offered directly to children · Document repository
- The age threshold applied per Member State, with evidence the applicable national lower age was checked rather than assumed · Document repository
- Parental authorisation records where the user is below the threshold, including the verification carried out on the parent · Document repository
governing documentDocuments that govern the control
- The age assurance mechanism, and the reasoning for why it is a reasonable effort given available technology · Document repository
- The procedure and records for what happens when a user is identified as under age after registration · Policy repository / GRC workspace
First move
This control is evidenced by people and documents, not systems. Put the document under version control with an owner and review date, and log each review as a record with reviewer and date. Do not try to automate it.
Common gaps auditors find
- A self declared date of birth with no verification at all treated as reasonable effort
- A single threshold of 16 applied across the Union without checking the Member States that set 13, 14 or 15
- Parental consent captured from an email address that is never verified as belonging to a parent
- The service judged not child directed on the basis of its terms of use rather than its actual audience
Do this for your whole sheet
Paste the rows you run your controls from and get this mapping for every control at once, with the periodic-review ones flagged and a first move per row. No account for the first run.
Build my evidence sheetArt.7 Conditions for consent · Art.9 Processing of special categories of personal data