On July 18, 2023, the Personal Data Protection Commission (PDPC) launched a public consultation on the Proposed Advisory Guidelines on the Personal Data Protection Act for Children's Personal Data (Proposed Guidelines). In particular, the PDPC clarifies that, currently, the Advisory Guidelines on the PDPA for Selected Topics contain guidance on data activities for individuals under 21 years of age. Whereas, the Proposed Guidelines would apply to organizations that offer products or services that are likely to be accessed by children or are in fact accessed by children, even if the products or services are not targeted at children. Similarly, organizations that are data intermediaries or that retain children's personal data would also be expected to implement additional measures to protect children's personal data.

In particular, the PDPC fields questions including:

• how organizations should minimize the collection, use, and disclosure of children's personal data;
• in what situations should an organization conduct a Data Protection Impact Assessment (DPIA) before releasing products or services to children;
• when a child can give valid consent on their own behalf; and
• additional measures that organizations should undertake for the protection of children's data.

Public comments can be submitted via email to [email protected] until August 31, 2023.

You can read the press release here and the Proposed Guidelines here.