TIE Position on ePrivacy Regulation

Toy Industries of Europe welcomes the modernisation of the European privacy framework. Especially the move towards a more harmonised approach that recognises the borderless nature of the digital world.

As they review the ePrivacy Directive, we call on policy makers to:

• Agree principle-based, future-proof and pragmatic solutions that work in complement to the General Data Protection Regulation (GDPR);
• Make sure that any specific measures taken to protect children’s right to privacy are proportionate to the risk to their private life; in particular, these measures should not be detrimental to children’s other rights, like freedom of expression and access to information;
• Be aware of unintended consequences of policy decisions that may result in more intrusive information requests from parents, a downgraded online experience for children, or loss of free content.  In particular that children and their parents may be pushed towards alternatives that are less safe, and have not been designed with children in mind;
• Recognise the positive benefits of limited data collection activities in allowing companies to offer engaging and innovative digital offerings for children. Prohibiting all data collection is likely to lead to a significant decrease in the development of appropriate content and services for kids.

The full document is available here.