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Children's Online Safety Policy

A policy setting out protections for users under 18, covering age verification, parental consent, content restrictions, and data handling for minors.

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6 pages avgHigh riskRequired by law3 jurisdictions

What is a Children's Online Safety Policy?

A policy setting out protections for users under 18, covering age verification, parental consent, content restrictions, and data handling for minors.

Regulators across US, UK, EU treat a Children's Online Safety Policy as a baseline legal requirement. Without one, your business is immediately exposed to enforcement action — regardless of size or industry.

High-risk area: COPPA: FTC fines up to $51,744 per violation. UK ICO enforcement for Children's Code breaches.

Who Needs a Children's Online Safety Policy?

Platforms and apps that may be accessed by children under 13 (COPPA) or under 18 (UK Age Appropriate Design Code).

  • Any organisation that platforms and apps that may be accessed by children under 13 (coppa) or under 18 (uk age appropriate design code)
  • Businesses operating in US and UK
  • Anyone using third-party services that process data on your behalf

Legal Framework

COPPA, UK Children's Code (Age Appropriate Design Code), GDPR Article 8.

US

Applicable national and regional regulations

UK

UK GDPR — ICO enforcement

EU

EU GDPR — up to €20M or 4% turnover

What Your Children's Online Safety Policy Must Include

  1. 1

    Age Verification

    Age Verification — Clearly define age verification so users and regulators understand its scope and why it matters for your compliance obligations.

  2. 2

    Parental Consent Mechanism

    Parental Consent Mechanism — Clearly define parental consent mechanism so users and regulators understand its scope and why it matters for your compliance obligations.

  3. 3

    Data Collection Minimisation

    Data Collection Minimisation — Clearly define data collection minimisation so users and regulators understand its scope and why it matters for your compliance obligations.

  4. 4

    Profiling Restrictions

    Profiling Restrictions — Clearly define profiling restrictions so users and regulators understand its scope and why it matters for your compliance obligations.

  5. 5

    Nudge Techniques Prohibition

    Nudge Techniques Prohibition — Clearly define nudge techniques prohibition so users and regulators understand its scope and why it matters for your compliance obligations.

  6. 6

    Default Privacy Settings

    Default Privacy Settings — Clearly define default privacy settings so users and regulators understand its scope and why it matters for your compliance obligations.

  7. 7

    Complaint Mechanism

    Complaint Mechanism — Clearly define complaint mechanism so users and regulators understand its scope and why it matters for your compliance obligations.

  8. 8

    Content Moderation

    Content Moderation — Clearly define content moderation so users and regulators understand its scope and why it matters for your compliance obligations.

How to Write a Children's Online Safety Policy

Building a compliant Children's Online Safety Policy from scratch takes legal expertise and hours of research. Here is a framework covering the core steps:

  1. 1
    Step 1: Age Verification — Document this section completely and accurately. Vague or incomplete disclosures can be treated as violations even if the underlying practice is compliant.
  2. 2
    Step 2: Parental Consent Mechanism — Document this section completely and accurately. Vague or incomplete disclosures can be treated as violations even if the underlying practice is compliant.
  3. 3
    Step 3: Data Collection Minimisation — Document this section completely and accurately. Vague or incomplete disclosures can be treated as violations even if the underlying practice is compliant.
  4. 4
    Step 4: Profiling Restrictions — Document this section completely and accurately. Vague or incomplete disclosures can be treated as violations even if the underlying practice is compliant.
  5. 5
    Step 5: Nudge Techniques Prohibition — Document this section completely and accurately. Vague or incomplete disclosures can be treated as violations even if the underlying practice is compliant.
  6. 6
    Step 6: Default Privacy Settings — Document this section completely and accurately. Vague or incomplete disclosures can be treated as violations even if the underlying practice is compliant.
  7. 7
    Final step: Legal review — Review with qualified legal counsel before publishing, especially if operating in high-risk jurisdictions.

Common Mistakes to Avoid

  • Copying another website's Children's Online Safety Policy verbatim — Every business has different data flows. A generic copy may fail to disclose what you actually do, creating false statements that are worse than no policy at all.

  • Using vague or ambiguous language — Regulators and courts expect plain, specific language. Phrases like "we may share your data with partners" are too vague and regularly cited in enforcement actions.

  • Forgetting to update after product changes — Your Children's Online Safety Policy must reflect current practice. Outdated policies are a compliance liability — some regulators treat an outdated policy as a violation in itself.

  • Not making your Children's Online Safety Policy easy to find — Buried in a footer or behind multiple clicks, your policy may not meet the "easily accessible" standard required by most regulations.

  • Missing jurisdiction-specific requirements — A policy compliant in one jurisdiction may still fail in another. If you operate across US and UK, you need to address each framework's specific requirements.

How Often Should You Update Your Children's Online Safety Policy?

At minimum, review your Children's Online Safety Policy once a year — and immediately whenever you: change the data you collect, add new third-party tools, enter new jurisdictions, or experience a data incident.

Consequences of Non-Compliance

COPPA: FTC fines up to $51,744 per violation. UK ICO enforcement for Children's Code breaches.

Beyond financial penalties, non-compliance with Children's Online Safety Policy requirements can result in: reputational damage and loss of customer trust, app store removal (for mobile apps), inability to process payments (for ecommerce), and difficulty attracting enterprise customers who require compliance evidence.

Frequently Asked Questions

Is a Children's Online Safety Policy legally required?

Yes. A Children's Online Safety Policy is a legal requirement under COPPA, UK Children's Code (Age Appropriate Design Code), GDPR Article 8.. Operating without one puts your business at risk of regulatory enforcement action.

How long should a Children's Online Safety Policy be?

A typical Children's Online Safety Policy runs 6 pages. Length matters less than completeness — every required disclosure must be present, written in plain language that users can understand.

How often should I update my Children's Online Safety Policy?

At minimum, review your Children's Online Safety Policy once a year — and immediately after any business change.

What are the penalties for not having a Children's Online Safety Policy?

COPPA: FTC fines up to $51,744 per violation. UK ICO enforcement for Children's Code breaches.

Can I use a free Children's Online Safety Policy template?

Free templates are a starting point, not a solution. A template that was not drafted for your specific business, jurisdiction, and data practices may create false statements — which is legally worse than having no policy at all. Always customise any template and have it reviewed by qualified counsel.

Quick Facts

Status

Required by law

Risk if missing

High

Refresh cadence

Annually

Average length

6 pages

Jurisdictions covered

US, UK, EU

Legal basis

COPPA, UK Children's Code (Age Appropriate Design Code), GDPR Article 8.

Key points

  • UK Children's Code applies to all services likely accessed by under-18s
  • COPPA applies to children under 13 in the US
  • Default settings must be set to high privacy for children
  • Geolocation tracking of minors is heavily restricted
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PolicifyAI is a technology provider, not a law firm. The information on this page is for orientation only and is not legal advice. Generated templates are intended as a structured starting point for review by qualified counsel before publication.

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PolicifyAI is a technology provider, not a law firm. The information, templates, and automated outputs on this site are for general informational purposes only and do not constitute legal advice. Policies generated by PolicifyAI are software-assembled compliance documents designed to align with the requirements of relevant regulations — review by qualified legal counsel is recommended before publication. Use of this platform does not create a solicitor-client or attorney-client relationship.

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