Following its earlier contribution to the European Commission’s call for evidence on the Digital Services Act (DSA), EFPA has submitted a detailed response to the public consultation on the draft guidelines for protecting minors online.
EFPA welcomes the Commission’s comprehensive approach to ensuring children’s privacy, safety, and security on digital platforms, particularly the risk-based framework and the emphasis on privacy by design. The guidelines’ focus on measures such as age assurance, private-by-default accounts, and user controls aligns closely with EFPA’s prior recommendations.
However, EFPA has proposed enhancements to further strengthen the guidelines, including:
- Incorporate Specific Protections for Vulnerable Groups: While the draft mentions considering disabilities and accessibility needs, it could include a specific recommendation for platforms to conduct targeted risk assessments for minors with clearly defined vulnerabilities (e.g., intellectual disabilities, neurodevelopmental conditions) and to design or adapt specific protective measures accordingly.
- Strengthen Guidance on AI and Algorithmic Explainability: The draft could strengthen its stance by suggesting that recommender systems that significantly shape minors' online experiences be treated with a level of diligence akin to high-risk AI systems under the EU AI Act's principles. Beyond stating that platforms should explain why content was recommended, it could encourage the development of genuinely child-friendly explanations of how algorithmic decisions are made.
- Explicitly Call for and Facilitate Specific Research: Add a section that more explicitly encourages and calls for research in areas highlighted by EFPA, such as the impact of specific online activities (beyond generic screen time) on youth mental health, including on issues like suicidal behaviour. It could also suggest that the Commission or Member States explore mechanisms to facilitate researcher access to appropriately anonymised and aggregated platform data for such research, adhering to open science principles and data protection regulations. The draft could more strongly encourage platforms to establish ethical frameworks for sharing privacy-protected, anonymised, and aggregated data with independent researchers for specific studies on youth mental health.
EFPA remains committed to supporting policies that safeguard children’s wellbeing in digital environments, promoting evidence-based and psychologically informed measures within the framework of the DSA.
For more details on EFPA’s previous contribution, visit:
https://www.efpa.eu/efpa-contributes-european-commission-call-evidence-digital-services-act-guidelines-enforce
