Electronics Guide

Overview and Scope

The Children's Online Privacy Protection Act, enacted in 1998 and implemented through the COPPA Rule administered by the Federal Trade Commission, establishes the primary framework in the United States for protecting children's privacy online. COPPA applies to operators of commercial websites, online services, and mobile applications that are either directed to children under 13 or have actual knowledge that they are collecting personal information from children under 13. The law imposes significant obligations regarding notice, consent, data handling, and parental rights.

The definition of "operator" under COPPA extends beyond those who directly collect information from children to include parties who collect personal information from children through websites or services operated by others if they have actual knowledge of such collection. This means that advertising networks, analytics providers, and plug-in providers may have COPPA obligations when integrated into child-directed services. The reach of COPPA also extends to foreign-based operators that are under the jurisdiction of the FTC and direct their websites or services to children in the United States.

Determining whether a website or service is "directed to children" involves considering several factors: the subject matter of the site, visual content, use of animated characters or child-oriented activities and incentives, music and other audio content, age of models, presence of child celebrities or celebrities who appeal to children, language or other characteristics of the site, and whether advertising promoting or appearing on the site is directed to children. A site need not be exclusively for children to be considered directed to children if children are one of its target audiences.

Personal Information Under COPPA

COPPA defines personal information broadly to encompass not only obvious identifiers but also less apparent data that can be used to contact or identify a child. The categories of personal information include: first and last name; home or other physical address including street name and city or town; online contact information such as email address or any other identifier that permits direct contact; screen name or username where it functions as online contact information; telephone number; Social Security number; a photograph, video, or audio file containing a child's image or voice; geolocation information sufficient to identify a street name and city or town; and persistent identifiers that can recognize a user over time and across different websites or online services.

The inclusion of persistent identifiers as personal information has significant implications for electronics design. Cookies, IP addresses, unique device identifiers, customer numbers held in cookies, and similar tracking mechanisms all qualify as personal information when they can be used to recognize a user over time and across different sites. This means that even services that do not collect names or contact information may be subject to COPPA if they use standard web tracking technologies with children. The only exception is for persistent identifiers used solely for supporting internal operations of the site, such as maintaining or analyzing the functioning of the site, serving contextual advertising, or capping ad frequency.

The FTC has issued guidance clarifying that personal information extends to information combined with other data to achieve the purposes outlined in the personal information categories. For example, a first name combined with geolocation that can identify a street would constitute personal information, even though the first name alone might not. This combination principle requires careful analysis of all data elements collected and how they might be combined to identify or contact a child.

Notice Requirements

COPPA imposes detailed notice requirements at two levels: a comprehensive privacy policy posted on the website or service, and direct notice to parents before collecting personal information from their children. The privacy policy must be clearly and prominently linked from the homepage and from any area of the site where personal information is collected from children. The policy must state the contact information of all operators collecting personal information through the site, describe the types of personal information collected and how it is collected, explain how the information is used and whether it is disclosed to third parties, and describe parental rights regarding their children's information.

Direct notice to parents must be provided before collecting, using, or disclosing personal information from children, and must be sent to the parent's email address or through another method reasonably calculated to reach the parent. The direct notice must include all information required in the privacy policy plus a statement that the operator wishes to collect personal information from the child, that the parent's consent is required, the specific personal information the operator seeks to collect, how the parent can provide consent, and a hyperlink or URL to the online notice.

The notice requirements demand that information be presented in a clear, understandable manner. Technical jargon, legal language, and complex sentence structures should be avoided. Given that children themselves may read these notices, clarity is especially important. Some operators have found success with layered notices that provide a simple summary with links to more detailed information for parents who want it.

Verifiable Parental Consent

Before collecting personal information from children, operators must obtain verifiable parental consent using a method reasonably calculated to ensure that the person providing consent is the child's parent. The FTC has approved several consent mechanisms, recognizing that appropriate methods may vary depending on the circumstances. Acceptable methods include: providing a consent form to be signed by the parent and returned via mail, fax, or electronic scan; requiring the parent to use a credit card, debit card, or other online payment system that provides notification of each transaction; having the parent call a toll-free telephone number staffed by trained personnel; having the parent connect via video conference with trained personnel; and verifying a parent's identity by checking a form of government-issued identification against databases of such information.

For internal uses only, where personal information will not be disclosed to third parties, a modified consent process called "email plus" may be used. Under this method, the operator sends an email to the parent seeking consent, and then sends a confirming email to the parent after consent is received. The parent must be informed that they may revoke consent at any time. This lighter-weight mechanism acknowledges that the risks of internal-only use are generally lower than when information is shared externally.

The FTC has also adopted a voluntary approval process for new consent mechanisms. Technology advances may enable new methods of verifying parental identity that are both reliable and user-friendly. Organizations can apply to the FTC for approval of innovative consent methods, and approved methods become available for use by any operator. This process has facilitated the development of knowledge-based authentication systems and other novel approaches that balance security with usability.

Parental Rights and Operator Obligations

COPPA provides parents with substantial rights regarding their children's personal information. Parents must be given the opportunity to refuse to permit further collection or use of the child's information and to direct the operator to delete information collected from the child. Parents have the right to review the personal information collected from their child, and operators must respond to such requests within a reasonable time. Before providing access to personal information, operators must take steps to verify that the requestor is the child's parent, using a higher standard of verification than would be required for initial consent.

Operators must not condition a child's participation in a game, prize offer, or other activity on the child disclosing more personal information than is reasonably necessary to participate. This prohibition on contingent data collection reflects the principle of data minimization and prevents operators from exploiting children's desire to participate in activities to extract unnecessary personal information. Operators must establish and maintain reasonable procedures to protect the confidentiality, security, and integrity of personal information collected from children.

Operators must also maintain records of the information they collect and their consent practices. The COPPA Rule requires retention of records for as long as the information is maintained and then for an additional period determined by the FTC. These records must be available for review by the FTC upon request and serve as evidence of compliance with the Rule's requirements.

Safe Harbor Programs

The COPPA Rule provides for FTC approval of self-regulatory guidelines, known as safe harbor programs, that implement the protections of the Rule. Organizations that comply with approved safe harbor guidelines receive a presumption of compliance with COPPA. Safe harbor programs must include a comprehensive privacy policy, an audit or review of subject operators for compliance, disciplinary mechanisms for non-compliant operators, and mandatory annual reporting to the FTC.

Several organizations operate FTC-approved safe harbor programs, including the Children's Advertising Review Unit of the Better Business Bureau, the Entertainment Software Rating Board, PRIVO, TRUSTe/TrustArc, Aristotle International, and kidSAFE. These programs provide guidance, certification, and ongoing compliance monitoring for member organizations. Participating in a safe harbor program can reduce compliance burden by providing clear standards and expert guidance, though it does not eliminate the underlying obligations or prevent FTC enforcement in cases of violations.

The safe harbor model has been effective in raising compliance levels within participating sectors, particularly in gaming and children's media. However, the FTC retains enforcement authority and has taken action against both operators and safe harbor programs when violations occur. The benefits of safe harbor participation include access to compliance expertise, credibility with parents and regulators, and the presumption of compliance, but organizations must genuinely implement program requirements rather than treating participation as merely a badge.

UK Age Appropriate Design Code

The United Kingdom's Age Appropriate Design Code, also known as the Children's Code, came into force in September 2021 under the Data Protection Act 2018. The Code establishes 15 standards of age-appropriate design that apply to information society services likely to be accessed by children under 18 in the UK. Unlike COPPA's focus on children under 13, the UK Code extends protection to all minors, recognizing that older children and teenagers also require protection from certain data practices, albeit potentially different protections than younger children.

The Code's 15 standards cover: best interests of the child, which requires that the child's best interests be a primary consideration when designing and developing services; data protection impact assessments, requiring assessment of and mitigation of risks to children; age-appropriate application, requiring different approaches for different age ranges; transparency, requiring that privacy information be provided in age-appropriate ways; detrimental use of data, prohibiting use of children's data in ways that are detrimental to their wellbeing or that go against codes of practice and industry guidance; policies and community standards, requiring that published terms, policies, and community standards are upheld; default settings, requiring high privacy settings by default; data minimization, requiring collection of only the minimum data necessary; data sharing, requiring that children's data not be disclosed unless there is a compelling reason; geolocation, requiring that geolocation options be switched off by default; parental controls, requiring that children be given age-appropriate information about controls when they are activated; profiling, requiring that profiling be switched off by default unless there is a compelling reason; nudge techniques, prohibiting nudge techniques that lead children to provide unnecessary data or weaken privacy protections; connected toys and devices, requiring that connected toys and devices include effective standards of data protection; and online tools, requiring that prominent, accessible tools are provided to help children exercise their data protection rights.

The Information Commissioner's Office enforces the Code as part of its broader data protection mandate. While the Code is technically binding only on services offered to UK children, its influence extends globally. Major technology companies have implemented Code-compliant features worldwide rather than maintaining separate UK versions, effectively making the Code's standards international best practice. The Code has also influenced regulatory thinking in other jurisdictions considering similar requirements.

California Age-Appropriate Design Code Act

California enacted the Age-Appropriate Design Code Act in 2022, which became operative on July 1, 2024, making California the first US state to adopt comprehensive age-appropriate design requirements modeled on the UK Code. The California law applies to businesses that provide online services, products, or features that are likely to be accessed by children under 18. Like the UK Code, California's law extends protection beyond the under-13 age group covered by COPPA to encompass all minors.

The California law requires covered businesses to configure default privacy settings to offer a high level of privacy unless the business can demonstrate a compelling reason for a different default setting. Businesses must provide privacy information, terms of service, policies, and community standards in clear language suited to the age of children likely to access the service. They must complete data protection impact assessments before offering new services likely to be accessed by children and every two years thereafter, addressing specific concerns including whether the design could harm children, whether the design uses dark patterns, and whether data collection is necessary.

Significant restrictions apply to profiling, geolocation, and features that may be harmful to children. Profiling of children is prohibited unless the business can demonstrate that there are appropriate safeguards for children and that profiling is necessary to provide the service. Precise geolocation information may not be collected by default. Businesses may not use children's personal information in ways that are materially detrimental to their physical health, mental health, or wellbeing, or use dark patterns to lead children to provide unnecessary personal information, forego privacy protections, or take actions that harm their wellbeing.

Impact on Electronics Design

Age-appropriate design codes have significant implications for electronics manufacturers and service providers. Products and services that may be accessed by children must be designed with children's needs and vulnerabilities in mind from the outset. This affects decisions about default settings, data collection practices, user interface design, and feature implementation. The design process must incorporate child-specific considerations at every stage rather than treating children as an afterthought or edge case.

Default settings receive particular attention under these codes. The general principle is that settings affecting privacy and safety should default to the most protective option, with any less protective options requiring affirmative user action to enable. For devices or services likely to be used by children, this means that features like location tracking, personalized advertising, social features, and data sharing should be disabled by default. Users, or their parents, can choose to enable these features if they provide value, but the baseline experience must protect children's interests.

Data protection impact assessments specific to children are required before launching products or services. These assessments must consider the specific risks that the product poses to children of different ages, whether design features could harm children's physical or mental health, how the product complies with relevant age-appropriate design requirements, and what measures are implemented to mitigate identified risks. The assessment process requires cross-functional input and should be documented to demonstrate compliance.

Age-Based Differentiation

Age-appropriate design recognizes that children of different ages have different capabilities, vulnerabilities, and needs. A five-year-old has very different comprehension abilities than a fifteen-year-old, and design decisions appropriate for one age group may be inappropriate for another. Regulatory frameworks increasingly require age-differentiated approaches that calibrate protections to the developmental stage of the user.

The developmental approach to age-appropriate design considers cognitive, social, and emotional development at different ages. Young children typically cannot understand abstract concepts like privacy or give meaningful consent. They may not distinguish between commercial and non-commercial content or understand when they are being manipulated. Older children may have greater understanding but remain vulnerable to social pressure, may underestimate long-term consequences of their actions, and are particularly susceptible to design patterns that exploit their desire for social validation.

Implementing age-based differentiation requires some mechanism for determining user age, which creates its own challenges. Age verification methods must balance accuracy with privacy concerns and usability. The most protective approach treats all users as children unless age is verified, but this may impact the experience for adult users. Self-reported age is easily circumvented but may be appropriate for lower-risk situations. More robust verification methods such as document verification or credit card confirmation provide greater assurance but raise privacy and accessibility concerns.

Self-Declaration and Age Gates

The simplest form of age verification is self-declaration, where users state their age or confirm that they meet an age threshold. Age gates typically present users with a date of birth entry field or a simple confirmation button. While easy to implement and non-intrusive, self-declaration provides minimal assurance of accuracy because users can easily misrepresent their age. Studies consistently show that children routinely claim to be older to access age-restricted content or services.

Despite their limitations, self-declaration mechanisms remain common because they impose minimal friction on legitimate users and minimal data collection obligations on service providers. For services where the consequences of age misrepresentation are relatively minor, self-declaration may be deemed proportionate. However, regulatory expectations are shifting toward more robust verification for services that pose meaningful risks to children. The UK Age Appropriate Design Code specifically states that service providers should not use self-declaration alone when they have significant risks to children.

Implementations of age gates vary in their resistance to circumvention. Simple yes/no confirmations provide no meaningful barrier. Date of birth fields with no validation are easily bypassed but at least require users to think about what age they claim. Some services implement neutral age gates that do not reveal the age threshold, making it harder for users to know exactly what to enter to bypass the gate. However, all self-declaration methods ultimately rely on user honesty.

Document-Based Verification

Document-based age verification uses government-issued identity documents such as passports, driver's licenses, or national identity cards to verify user age. The user submits an image of their document, which is then processed to extract age-related information. Modern document verification systems use optical character recognition, document authentication algorithms, and sometimes biometric matching to verify that the document is genuine and belongs to the presenting user.

Document verification provides high assurance of age when implemented correctly. The challenge lies in balancing verification accuracy with user privacy and experience. Requiring users to submit identity documents creates privacy concerns about document storage and potential misuse. Users may be reluctant to share sensitive identity information with online services, particularly those they perceive as low-trust. The verification process adds friction that may cause users to abandon services.

Privacy-preserving approaches to document verification can address some concerns. Systems that verify age without retaining the identity document, use zero-knowledge proofs to confirm age without revealing other information, or employ tokenized verification where a trusted third party confirms age without sharing documents with the service provider all reduce privacy risks while maintaining verification assurance. Standards for privacy-preserving age verification are emerging, with the UK Age Verification Providers Association publishing a code of conduct for member organizations.

Payment-Based Verification

Credit cards and other payment methods are generally issued only to adults, making payment-based verification a practical proxy for age verification in many contexts. COPPA explicitly recognizes credit card verification as an acceptable method for obtaining verifiable parental consent. The premise is that if someone can complete a transaction using a credit card, they are more likely to be an adult or acting with adult authorization.

Payment verification is particularly effective when the service has a natural payment interaction point. Subscription services, in-app purchases, and premium content can all incorporate payment as part of their user flow while simultaneously obtaining age verification. The verification is relatively frictionless for users who intend to pay anyway and provides a meaningful barrier to underage access.

Limitations of payment verification include the increasing availability of debit cards and prepaid cards to minors, the ability of children to use their parents' cards without permission, and the inapplicability of payment verification to free services. For these reasons, payment verification is most appropriate as one element of a comprehensive verification approach rather than a sole reliance point. It also assumes that the payment account holder authorized the transaction, which may not always be the case.

Biometric and AI-Based Estimation

Advances in artificial intelligence have enabled age estimation systems that analyze facial images or voice samples to estimate user age. Facial age estimation uses computer vision algorithms trained on datasets of faces of known ages to predict the age of a new face. These systems can provide real-time age estimates without requiring users to submit identity documents, offering a potentially frictionless verification experience.

Age estimation technology has achieved reasonable accuracy for distinguishing adults from children, though accuracy varies depending on the specific age threshold and the demographics of the user population. Accuracy tends to be higher for distinguishing young children from adults than for distinguishing teenagers from young adults. Some systems provide confidence scores along with age estimates, enabling risk-based decisions about whether additional verification is needed.

Privacy and bias concerns surround biometric age estimation. Facial analysis involves processing biometric data, which is considered sensitive under many data protection frameworks. Users may be uncomfortable with their faces being analyzed, even if images are not retained after analysis. Age estimation algorithms have shown demographic biases, with accuracy varying by race, gender, and other characteristics. Services implementing biometric age estimation must address both the technical performance and the ethical implications of these systems.

Third-Party Verification Services

Third-party age verification services allow service providers to verify user age without directly handling identity documents or implementing verification technology themselves. These services typically operate by maintaining relationships with authoritative data sources such as credit bureaus, mobile operators, or government databases that can confirm user age based on provided information. The service provider sends user-provided information to the verification service, which returns a confirmation of age without sharing the underlying identity data.

Federated verification approaches allow users to verify their age once and then use that verification across multiple services. Digital identity wallets and age verification credentials enable users to prove their age without revealing their exact birthdate or other identity information. Standards such as the World Wide Web Consortium's Verifiable Credentials provide technical frameworks for portable, privacy-preserving age credentials.

Selection of third-party verification services requires due diligence on accuracy, privacy practices, and regulatory compliance. Service providers should understand what data the verification service collects, how that data is used and retained, what assurance level the service provides, and whether the service complies with applicable data protection requirements. The provider remains responsible for appropriate verification under applicable law, so reliance on a third-party service does not eliminate the need to understand and validate the verification approach.

Methods for Obtaining Consent

Parental consent mechanisms must balance the regulatory requirement for verification with practical usability for families. The most secure verification methods impose significant friction that may deter legitimate use, while lighter-weight methods may be easier to circumvent. The appropriate balance depends on the risks involved, with higher-risk data processing justifying more robust verification.

Email-based consent, particularly the "email plus" method permitted under COPPA for internal uses, provides a practical approach for lower-risk situations. The operator sends an email to a parent-provided email address seeking consent and sends a confirming email after consent is received. Parents are informed that they may revoke consent at any time. While children could theoretically provide their own email address, this method is appropriate when the consequences of circumvention are limited.

More robust verification methods for parental consent include signed consent forms returned by mail, fax, or electronic scan; credit card or other payment mechanism providing transaction notification; toll-free telephone calls to trained personnel; video conference with trained personnel; and government ID verification. The FTC has approved these methods as meeting COPPA's requirement for verification reasonably calculated to ensure that the person providing consent is the parent.

Consent Interface Design

The design of consent interfaces significantly affects both compliance and user experience. Consent requests should clearly explain what data is being collected, how it will be used, who it will be shared with, and how long it will be retained. Language should be appropriate for a general adult audience, avoiding technical jargon while maintaining accuracy. The request should clearly identify what action constitutes consent and what happens if consent is not provided.

Progressive consent approaches provide information in manageable portions rather than overwhelming parents with lengthy disclosures. Initial screens can summarize key points with options to access more detailed information. This layered approach respects parents' time while ensuring that comprehensive information is available for those who want it. However, key information necessary for informed consent should not be buried in deeper layers.

The timing and context of consent requests affect parent comprehension and decision quality. Consent requested at account creation allows parents to make informed decisions before data collection begins. In-context consent at the moment a feature is first used provides relevant information when it is most meaningful. Both approaches have merit, and comprehensive consent programs may combine them. Consent should never be requested in ways that pressure parents into hasty decisions or obscure the implications of their choices.

Ongoing Parental Control

Beyond initial consent, parents must have ongoing control over their children's data and online experiences. COPPA requires that parents be able to review the information collected from their child, refuse further collection or use, and direct deletion of collected information. These rights must be practical to exercise, meaning that operators must provide accessible mechanisms for parents to manage their children's information.

Parent dashboards and control panels provide centralized interfaces for viewing and managing children's data and settings. Effective dashboards display what information has been collected, show current privacy and safety settings, enable modification of settings and consent, and provide clear processes for data access and deletion requests. The dashboard should be easy to find, perhaps linked from the service's privacy policy and settings menu.

Parental controls may extend beyond data management to include content restrictions, time limits, purchase controls, and communication restrictions. The UK Age Appropriate Design Code requires that when parental controls are activated, children be given age-appropriate information about what controls are in place. This transparency principle recognizes that children have their own interests and should understand the parameters of their online experience, while still allowing parents to set appropriate boundaries.

Consent Revocation and Data Deletion

Consent withdrawal must be as easy as consent provision. Parents should be able to revoke consent through the same channels used to provide it, without requiring disproportionate effort. Upon consent revocation, the operator must stop collecting information from the child and delete previously collected information unless retention is required for other legal purposes.

Deletion requests must result in actual deletion of personal information, not merely deactivation or archiving. This includes information in backup systems, though reasonable timeframes for backup deletion are acceptable. Operators should have documented procedures for processing deletion requests that ensure complete removal of information from all systems where it resides.

The practical implications of deletion should be explained to parents. If deleting information will affect the child's ability to use the service, this should be clear. Some information may need to be retained for legal or safety reasons, and these limitations should be disclosed. Transparency about what happens when consent is revoked helps parents make informed decisions about whether to revoke consent and understand the consequences if they do.

Video Game Rating Systems

Video game content rating systems provide standardized age recommendations and content descriptors that help parents make informed choices about games for their children. The Entertainment Software Rating Board (ESRB) rates games in the United States and Canada, using categories ranging from Early Childhood (EC) for content suitable for ages 3 and older to Adults Only (AO) for content suitable only for adults 18 and older. The ESRB also provides content descriptors identifying specific content elements such as violence, language, and online interaction capabilities.

The Pan European Game Information (PEGI) system serves Europe with age categories of 3, 7, 12, 16, and 18. PEGI uses content descriptors including violence, bad language, fear, gambling, sex, drugs, discrimination, and in-game purchases. Other regions have their own rating systems, including the Computer Entertainment Rating Organization (CERO) in Japan, the Game Rating and Administration Committee (GRAC) in South Korea, and the Australian Classification Board.

Game hardware and digital storefronts typically incorporate rating information into their systems. Parental control features on consoles and mobile devices can restrict access to games above a selected rating threshold. Digital stores display rating information prominently and may require age verification for mature-rated content. These technical implementations make rating information actionable, allowing parents to enforce rating-based restrictions through platform controls.

Film and Television Ratings

Motion picture and television content rating systems predate digital media and provide familiar frameworks that have been adapted for streaming and digital distribution. The Motion Picture Association (MPA) film rating system in the United States uses categories from G (General Audiences) through NC-17 (No One 17 and Under Admitted), with content-specific explanations for each rating. Television content ratings provide similar guidance for broadcast and streaming content.

Streaming services typically implement parental controls that leverage content ratings to restrict what children can access. Netflix, Disney+, Amazon Prime Video, and other services allow parents to set profile-level restrictions based on content ratings. These controls can limit profiles to content below a specified rating or require a PIN to access restricted content. Some services offer dedicated children's profiles that automatically filter to age-appropriate content.

The challenge of rating user-generated and rapidly proliferating content has led to hybrid approaches combining human review, automated classification, and user reporting. Platforms hosting user content may apply their own content policies and age restrictions, using machine learning systems to flag potentially inappropriate content for review. These systems must balance the impracticality of manually reviewing all content against the risks of inappropriate content reaching children.

App Store Age Ratings

Mobile application stores maintain their own age rating systems that determine visibility and download restrictions. Apple's App Store uses age ratings of 4+, 9+, 12+, and 17+, with content descriptions for each category. Google Play uses content ratings aligned with the International Age Rating Coalition (IARC) system, providing region-appropriate ratings based on a single questionnaire completed by developers. These ratings affect whether apps appear in search results for users with parental controls enabled and whether age verification is required for download.

The IARC system represents an effort to harmonize age ratings across regions and platforms. Developers complete a standardized questionnaire about their app's content, and the system generates appropriate ratings for different regions based on local rating standards. This approach reduces the burden on developers who would otherwise need to obtain separate ratings for each market while ensuring that users see familiar, locally appropriate ratings.

Self-certification by developers creates potential for inaccurate ratings, whether through misunderstanding of criteria or intentional misrepresentation. App stores conduct some review of ratings, particularly for apps flagged by users, but comprehensive verification is impractical given the volume of apps. Parents should understand that app store ratings are primarily developer-declared and may not perfectly reflect content, making ongoing monitoring of children's app use important.

International Rating Considerations

Content ratings vary significantly across jurisdictions, reflecting different cultural norms and regulatory frameworks. Content considered appropriate for children in one country may be restricted in another. Violence, sexuality, substance use, gambling, and other content categories receive different treatment depending on local standards. Products distributed internationally must navigate these variations.

Electronics manufacturers and service providers distributing content internationally typically implement the most restrictive applicable ratings or provide region-specific controls. Geolocation can enable automatic selection of appropriate regional standards, though VPN use and travel can complicate geographic restrictions. User-configurable region settings allow parents to select standards matching their values regardless of current location.

Rating harmonization efforts such as IARC aim to reduce complexity while respecting regional differences. These systems translate between regional rating standards, enabling developers to obtain multiple regional ratings through a single process. However, fundamental differences in rating approaches mean that perfect harmonization is not achievable, and some content may receive very different ratings in different regions.

Health-Based Recommendations

Medical and public health organizations have issued guidelines addressing children's media use based on developmental and health considerations. The American Academy of Pediatrics recommends avoiding digital media use for children under 18 to 24 months except for video chatting, limiting screen use to one hour per day of high-quality programming for children 2 to 5 years old, and ensuring that screen time does not interfere with adequate sleep, physical activity, and other healthy behaviors for children 6 and older. The World Health Organization has issued similar recommendations emphasizing the importance of physical activity and limiting sedentary screen time.

These guidelines inform both regulatory expectations and product design decisions. While screen time recommendations are not typically legally binding, they establish a framework of expectations that regulators and courts may reference when evaluating whether products appropriately protect children. Products designed to maximize engagement without regard to health impacts may face criticism and potential liability.

The nuance in health guidance is often lost in public discourse. Quality of screen time matters as much or more than quantity. Educational content, video calls with family members, and creative activities have different implications than passive video consumption or exploitative games designed to maximize addictive engagement. Design decisions should consider not just how much time children spend with a product but what they do during that time and how the product affects their broader wellbeing.

Screen Time Control Implementation

Major device platforms include screen time controls that allow parents to monitor and limit children's device use. Apple's Screen Time, Google's Family Link, and Microsoft Family Safety provide tools for setting daily time limits, scheduling downtime, restricting specific apps, and monitoring usage patterns. These system-level controls apply across apps, providing consistent enforcement that individual apps cannot circumvent.

Effective screen time controls balance restriction with flexibility. Fixed daily limits may not account for legitimate variations in use patterns, such as longer use during travel or for school projects. More sophisticated controls allow for different limits on different days, different limits for different categories of content, the ability to extend time on request, and gradual warnings as limits approach rather than abrupt cutoffs.

Device-level controls have limitations. Children who use multiple devices may encounter different limits on each. Apps can sometimes circumvent controls through various technical means, though platforms increasingly close these loopholes. Screen time spent on devices not controlled by parents, such as those at friends' homes or school computers, is not captured. These limitations mean that technical controls should be viewed as one element of a comprehensive approach that includes ongoing communication and supervision.

App-Level Time Management

Individual apps may implement their own screen time or break-reminder features, particularly those designed for children or known to encourage extended use. These features complement device-level controls by providing context-specific guidance aligned with the nature of the app. A game might implement natural stopping points, an educational app might suggest breaks between learning sessions, and a video service might disable autoplay for children's profiles.

The UK Age Appropriate Design Code specifically addresses features that encourage prolonged use, prohibiting nudge techniques that lead children to spend more time on services than they would otherwise choose. This prohibition targets design patterns such as infinite scroll, autoplay, notifications timed to pull users back, and reward systems designed to create habitual use. While these patterns may be acceptable for adult users who can exercise informed choice, they are considered manipulative when applied to children.

Positive approaches to time management encourage healthy use patterns rather than simply restricting time. Features such as celebration of learning milestones rather than time spent, natural episode or level endings rather than cliffhangers, activity summaries that encourage reflection on time use, and prompts suggesting alternative activities can help children develop healthy digital habits. These approaches align with the principle that children's best interests should guide design decisions.

Sleep and Wellbeing Considerations

Screen use, particularly before bedtime, can interfere with children's sleep through multiple mechanisms including blue light exposure that suppresses melatonin production, mental stimulation that impedes wind-down, and displacement of sleep time. Sleep deprivation during childhood affects cognitive development, emotional regulation, physical health, and academic performance. Products used by children should be designed with awareness of these impacts.

Technical features addressing sleep impacts include blue light reduction modes that shift display colors toward warmer tones in evening hours, scheduled downtime that enforces device-free periods before bedtime, and bedtime reminders that prompt children to wind down. Some devices can automatically enable these features based on time of day, while others require parent or user activation.

Content and interaction design also affects sleep-readiness. Exciting or stressful content immediately before bed can interfere with sleep regardless of blue light exposure. Features that encourage "just one more" engagement work against natural stopping points. Products designed with children's wellbeing in mind should consider how their design affects not just engagement metrics but the broader health of their users.

Student Privacy Regulations

Educational technology used in schools must comply with student privacy regulations in addition to general children's privacy requirements. In the United States, the Family Educational Rights and Privacy Act (FERPA) protects the privacy of student education records, while the Protection of Pupil Rights Amendment (PPRA) addresses surveys and evaluations. Many states have enacted additional student privacy laws that impose specific requirements on educational technology vendors.

FERPA applies to educational agencies and institutions receiving federal funding, granting parents rights to access and seek correction of education records and limiting disclosure of personally identifiable information without consent. When schools use educational technology, student data in those systems may constitute education records subject to FERPA. Schools must ensure that vendors provide appropriate privacy protections, typically through contractual provisions designating the vendor as a school official with legitimate educational interest.

State student privacy laws often go beyond FERPA in restricting commercial use of student data. Laws such as the Student Online Personal Information Protection Act (SOPIPA) in California prohibit operators of educational sites from using student data for targeted advertising, creating advertising profiles, selling student information, or disclosing student information except for K-12 school purposes. Similar laws in other states create a patchwork of requirements that educational technology vendors must navigate.

Learning Standards and Accessibility

Educational technology should align with established learning standards that define what students should know and be able to do at each grade level. In the United States, the Common Core State Standards and state-specific standards provide frameworks for curriculum alignment. Products claiming educational value should demonstrate how their content and pedagogy support recognized learning objectives.

Accessibility requirements ensure that educational technology is usable by students with disabilities. Section 504 of the Rehabilitation Act and the Americans with Disabilities Act require that students with disabilities have equal access to educational programs, including technology-delivered instruction. The Web Content Accessibility Guidelines (WCAG) provide technical standards for digital accessibility that educational technology should meet.

Effective educational technology incorporates universal design principles that benefit all learners, not just those with identified disabilities. Multiple means of representation, expression, and engagement accommodate diverse learning styles and needs. Features such as adjustable text size, audio alternatives, closed captions, simplified interfaces, and scaffolded instruction help all students while being essential for some.

Research and Assessment Ethics

Educational technology often involves collection of detailed data about student learning, raising questions about research ethics and appropriate use of assessment data. Research involving children, including studies using educational technology data, is subject to ethical review requirements. The Common Rule governing federally funded research requires institutional review board approval for human subjects research, with special protections for research involving children.

Even when formal research protocols do not apply, ethical principles should guide data use. Learning analytics and adaptive systems that collect detailed data about student performance should use that data to benefit students rather than for commercial purposes unrelated to education. Transparency about how student data is used and meaningful opportunities for families to understand and control data use respect both privacy and autonomy.

Assessment data requires particular care given its potential consequences for students. Scores and evaluations can affect educational placements, grades, and opportunities. Systems that generate assessment data should be validated for their intended uses and should not be applied in high-stakes decisions without appropriate psychometric support. Algorithmic assessment systems should be evaluated for bias and fairness across student populations.

Connected Toy Privacy Concerns

Connected toys that incorporate microphones, cameras, location tracking, and internet connectivity create unique privacy risks for children. These toys can collect sensitive information about children in intimate settings such as bedrooms and play areas. The combination of always-on listening, cloud connectivity, and often inadequate security has led to significant privacy breaches and regulatory concern.

High-profile incidents have illustrated connected toy risks. The CloudPets data breach exposed voice recordings of children. The Genesis Toys complaint to the FTC alleged COPPA violations and unfair collection of voice data. The My Friend Cayla doll was banned in Germany as an illegal surveillance device. These cases demonstrate that connected toys must be designed with security and privacy as primary concerns, not afterthoughts.

Regulatory scrutiny of connected toys has increased. The FTC has brought enforcement actions against connected toy manufacturers for COPPA violations. The UK Age Appropriate Design Code specifically addresses connected toys and devices, requiring that they include effective standards of privacy and security. European consumer organizations have filed complaints against various smart toys. Manufacturers must anticipate heightened attention to this product category.

Physical Safety Requirements

Connected toys must meet physical safety standards applicable to all toys, plus additional considerations arising from their electronic components. Traditional toy safety standards address choking hazards, sharp edges, toxic materials, and other physical risks. Electronic toys must additionally address battery safety, electrical shock risks, and potential hazards from overheating or malfunction.

In the United States, the Consumer Product Safety Commission enforces toy safety requirements under the Consumer Product Safety Act and the Consumer Product Safety Improvement Act. Toys must comply with the ASTM F963 toy safety standard and must not contain lead above specified limits. Third-party testing by accredited laboratories is required. Similar requirements apply in other jurisdictions, with the European EN 71 standard being particularly important for products sold in Europe.

Battery safety receives particular attention for connected toys given the use of lithium-ion batteries in many smart products. Proper battery compartment design prevents child access to batteries while allowing parent replacement. Charging systems must prevent overcharging and thermal runaway. Products should fail safely if batteries are damaged or defective. Battery safety standards such as UL 2054 and IEC 62133 provide detailed requirements.

Security Requirements for Smart Toys

Connected toys require robust security measures to protect against unauthorized access, data breaches, and malicious use. Security vulnerabilities in smart toys can enable eavesdropping on children, unauthorized communication with children, data theft, and use of the toy as an entry point for network attacks. The consequences of security failures in products used by children are particularly severe.

Basic security hygiene for connected toys includes encryption of data in transit and at rest, secure authentication preventing unauthorized access, secure update mechanisms maintaining protection over time, access controls limiting who can communicate with the toy, and data minimization reducing the impact of potential breaches. These measures should be implemented by default, with secure design embedded throughout the development process rather than added at the end.

Security requirements for IoT devices, including toys, are increasingly subject to regulation. The California IoT security law requires reasonable security features appropriate to the device's nature and function. The UK Product Security and Telecommunications Infrastructure Act requires compliance with security requirements for consumer connectable products. The European Cyber Resilience Act will impose comprehensive security requirements across the product lifecycle. Smart toy manufacturers must track and comply with this evolving regulatory landscape.

Physical Child Locks

Physical child locks prevent children from accessing dangerous features or components of electronic devices. Traditional applications include locks on appliance doors, covers for electrical outlets, and guards preventing access to moving parts. These mechanical safety features prevent injury from electricity, heat, sharp components, and other hazards.

Product safety standards specify child lock requirements for various appliance categories. IEC 60335-1 requires that household appliances be constructed so that during normal use there is adequate protection against accidental contact with live parts and dangerous moving parts. Specific parts of this standard address particular appliance types with their unique hazards. Compliance testing verifies that child locks effectively prevent child access while remaining usable for adults.

Child-resistant packaging requirements apply to products containing hazardous materials that children might ingest. Battery compartments in toys often require child-resistant fastening, typically screws that cannot be opened without tools. Button battery safety is a particular concern given the severe injuries that can result from battery ingestion, leading to requirements for secure battery compartments and packaging.

Digital Content Locks

Digital content locks restrict children's access to inappropriate content or features on electronic devices. Parental controls on devices, applications, and services enable parents to set restrictions appropriate to their children's ages and their family's values. These controls typically address content ratings, purchase restrictions, communication features, and privacy settings.

Platform-level parental controls provide system-wide restrictions that apply across applications. Operating systems from Apple, Google, and Microsoft include family safety features that can restrict app installation, limit screen time, filter web content, and monitor activity. These controls are typically managed through a parent's device or account, allowing remote configuration and monitoring.

Application-specific controls supplement platform controls with features tailored to particular services. Streaming services offer restricted profiles, social media platforms offer limited interaction modes, and games offer purchase controls. These application-level controls allow more granular configuration than platform controls can provide, such as restricting specific features while allowing others.

Purchase and Transaction Controls

Purchase controls prevent children from making unauthorized purchases through electronic devices. In-app purchases, digital content stores, and connected devices all present opportunities for children to spend money without parental authorization. High-profile cases of children incurring thousands of dollars in charges have led to both regulatory action and platform improvements.

The FTC has brought enforcement actions against companies that failed to obtain parental consent before charging for in-app purchases by children. The Apple, Google, and Amazon cases resulted in substantial refunds to affected families and commitments to improved practices. These cases established that existing consumer protection law requires meaningful consent before charges, even in freemium and free-to-play contexts.

Effective purchase controls require authentication before transactions, with configuration options appropriate for different ages. Young children's accounts might prohibit all purchases. Older children's accounts might allow purchases up to a limit or with parent approval for each transaction. Password or biometric requirements for purchases prevent unauthorized transactions by children who have access to a device. Notification of purchases to parents enables monitoring and rapid response to unauthorized activity.

Targeting Restrictions for Children

Advertising to children faces significant restrictions reflecting children's limited ability to understand commercial intent and resist persuasion. COPPA prohibits making personal information from children available for behavioral advertising unless verifiable parental consent is obtained. Age-appropriate design codes prohibit targeting children with personalized advertising based on their data.

Contextual advertising, which targets based on the content being viewed rather than user profiles, generally remains permissible for children's services. A children's educational app might display ads for other children's apps or educational products based on the app's category rather than the child's individual data. This distinction between contextual and behavioral advertising is fundamental to understanding what advertising models are permissible for children's services.

Self-regulatory frameworks supplement legal requirements. The Children's Advertising Review Unit (CARU) of the Better Business Bureau administers guidelines for advertising directed to children under 13. These guidelines address truthfulness, disclosure, safety, pressure tactics, and other concerns specific to children's advertising. While not legally binding, CARU guidelines influence industry practice and may be referenced by regulators.

Disclosure Requirements

Advertising directed to children must be clearly distinguishable from program content. The blurring of commercial and non-commercial content that is common in influencer marketing and branded content poses particular risks for children who may not recognize commercial intent. Regulatory guidance increasingly requires clear disclosure when content is sponsored, paid, or otherwise commercial in nature.

The FTC's Endorsement Guides require that material connections between advertisers and endorsers be clearly disclosed. For children's content, these disclosures must be understandable to children, which may require different approaches than disclosures in adult-oriented content. Simple language, prominent placement, and consistent formatting help children recognize when content is commercial.

Host selling, where program characters appear in advertising during or adjacent to their programs, is restricted for children's television under FCC rules. Similar principles apply to digital content, where the lines between entertainment and advertising are often even more blurred. Products and services marketed to children should maintain clear separation between content and advertising.

Problematic Product Categories

Certain product categories face heightened restrictions or outright prohibitions when marketed to children. Alcohol and tobacco advertising to children is broadly prohibited. Gambling advertising restrictions increasingly extend to gambling-like mechanics in games. Food and beverage advertising to children faces both regulatory and self-regulatory restrictions addressing childhood obesity concerns.

Loot boxes and similar randomized purchase mechanics in games have attracted regulatory attention as potential gambling. While regulatory classification varies by jurisdiction, many authorities have expressed concern about these mechanics when accessible to children. Belgium has prohibited loot boxes that can be purchased with real money. The UK Gambling Commission has indicated that it could regulate paid loot boxes as gambling if they meet the legal definition. Game designers should consider these concerns when implementing monetization mechanics.

Age-restricted products sold through electronic channels must implement appropriate age verification and must not target advertising to minors. Alcohol delivery services, cannabis dispensaries, vaping products, and similar restricted categories require robust age verification before purchase and should not employ advertising strategies that appeal to children.

Principle of Minimal Data Collection

Data minimization requires collecting only the personal information necessary for the specific purpose at hand. For children's services, this principle takes on particular importance given children's limited understanding of data practices and the long-term implications of data collected during childhood. Services should critically evaluate every data element they collect and eliminate any that are not strictly necessary.

COPPA explicitly prohibits conditioning a child's participation on disclosing more personal information than is reasonably necessary to participate. This prohibition prevents operators from leveraging children's desire to participate in activities to extract unnecessary data. Similar principles appear in the UK Age Appropriate Design Code's data minimization standard and other age-appropriate design frameworks.

Implementing data minimization requires examination of data collection at multiple levels. What categories of data are collected? Within each category, what specific data elements are collected? For each element, what is the specific purpose? Can that purpose be achieved with less data or with anonymized or aggregated data? This rigorous analysis often reveals that services collect significant amounts of data by default that provide little value while creating privacy risks.

Purpose Limitation

Purpose limitation requires that data collected for one purpose not be used for materially different purposes without appropriate consent. For children's data, this principle prevents collection under the guise of providing a service and then repurposing the data for advertising, profiling, or sale. Children and their parents who consent to data collection for a specific purpose reasonably expect that the data will be used only for that purpose.

Age-appropriate design frameworks reinforce purpose limitation for children's data. The UK Code prohibits using children's data in ways that could be detrimental to their wellbeing. The California Age-Appropriate Design Code Act prohibits using children's personal information in ways that are materially detrimental to their physical health, mental health, or wellbeing. These prohibitions go beyond traditional purpose limitation to restrict even authorized uses that harm children.

Technical and organizational measures should enforce purpose limitation. Data architectures that separate data by purpose, access controls that limit who can access data for each purpose, audit logging that tracks data access, and governance processes that review proposed new uses all contribute to effective purpose limitation. These measures make it harder for data collected for legitimate purposes to drift into inappropriate uses.

Retention Limits

Data should not be retained longer than necessary for the purpose for which it was collected. For children's data, shorter retention periods are generally appropriate given the sensitivity of data about children and the changing implications as children grow older. Information collected about a young child may be sensitive in ways that information about an adult is not, and may become increasingly inappropriate to retain as the child matures.

COPPA requires that operators establish and maintain reasonable procedures to protect the confidentiality, security, and integrity of personal information collected from children, which includes not retaining data longer than necessary. The UK Age Appropriate Design Code's data minimization standard requires that data not be retained for longer than necessary for the purpose for which it was collected.

Automatic deletion mechanisms enforce retention limits more reliably than manual processes. Systems should be configured to automatically delete children's data after appropriate retention periods, with those periods defined in advance based on actual necessity rather than indefinite retention as a default. Where data must be retained for legal or safety reasons, it should be appropriately secured and isolated from general use.

Deletion Rights Framework

The right to erasure, commonly known as the right to be forgotten, enables individuals to have their personal data deleted under certain circumstances. For children's data, this right takes on particular significance given that children may not fully understand the implications of their data being collected and that data collected during childhood may have lasting impacts on individuals as they mature.

COPPA provides parents the right to direct operators to delete personal information collected from their children. Upon such a request, operators must delete the child's personal information from their records. The right can be exercised at any time, regardless of whether the parent previously consented to collection. Operators must honor these requests promptly and thoroughly.

The GDPR provides a general right to erasure that applies to all personal data, with processing of children's data for information society services specifically identified as a circumstance where the right to erasure applies. The GDPR also recognizes that when consent for processing children's data was given while a minor, the now-adult individual may seek erasure of data collected during childhood.

Implementation Challenges

Implementing the right to erasure presents technical and operational challenges. Data may be stored in multiple systems, including production databases, backups, analytics platforms, and third-party services. Complete deletion requires identifying all locations where data resides and ensuring removal from each. Backup systems pose particular challenges because individual record deletion from backups is often technically difficult.

Third-party data sharing complicates erasure obligations. When children's data has been shared with processors or other third parties, erasure requests must be propagated to those parties. Operators must have visibility into where data has been shared and mechanisms to communicate and verify erasure by third parties. Contractual provisions should address how erasure requests will be handled throughout the data processing chain.

Documentation of erasure demonstrates compliance with deletion obligations. Records should capture what erasure requests were received, what actions were taken in response, what systems and third parties were addressed, and confirmation that deletion was completed. These records provide evidence of compliance and enable response to subsequent inquiries about whether data was properly deleted.

Exceptions and Limitations

The right to erasure is not absolute and is subject to various exceptions. Legal obligations to retain data, such as tax records or court-ordered preservation, may override deletion requests. Defense of legal claims may require retention of relevant data. Archival, research, or statistical purposes may justify retention under appropriate safeguards. Public interest considerations may limit erasure in certain contexts.

For children's data, exceptions should be applied narrowly. The strong interest in protecting children supports deletion as the default, with retention justified only when clearly necessary. Services should not rely on broad exceptions to avoid deleting children's data. When exceptions apply, they should be documented and data should be segregated from general use.

Transparency about limitations helps parents and children understand what will happen to their erasure requests. Privacy policies and response communications should clearly explain what data can be deleted, what data may need to be retained and why, and how retained data will be protected. This transparency supports informed decision-making about using services that collect children's data.

Default Setting Principles

Default settings represent the configuration that users experience without taking any action to change settings. For services used by children, these defaults are particularly important because children may not understand how to modify settings or appreciate the implications of different configurations. Age-appropriate design frameworks consistently require that defaults be configured to protect children's privacy and safety.

The UK Age Appropriate Design Code requires that settings be high privacy by default unless there is a compelling reason for a different default setting taking account of the best interests of the child. The California Age-Appropriate Design Code Act similarly requires configuring default privacy settings to offer a high level of privacy unless the business can demonstrate a compelling reason for a different default. These requirements flip the traditional approach of enabling features by default and requiring users to opt out.

Privacy by default means that personal data processing beyond what is strictly necessary for the service should require affirmative user action to enable. Location sharing, personalized advertising, social features, and data sharing with third parties should all be disabled by default for services used by children. Users who want these features can choose to enable them, but the baseline experience should protect privacy.

Implementation Approaches

Implementing privacy and safety by default requires systematic review of all product settings and features. For each setting that affects privacy or safety, the question is whether the default configuration maximizes protection. Features that collect additional data, share information, enable contact with strangers, or expose children to potentially harmful content should default to the restrictive option.

Technical implementation should enforce defaults at the code level rather than relying solely on interface choices. Default values should be coded into the system so that accounts start with protective settings. Any change from the default should require affirmative action by an authorized person, typically a parent for children's accounts. Audit logging should track who changed settings and when.

Testing should verify that defaults are correctly applied. Test accounts created through normal flows should be inspected to verify that settings match intended defaults. Regression testing should ensure that code changes do not inadvertently modify defaults. Compliance testing should compare actual defaults against regulatory requirements and internal policies.

Balancing Protection and Functionality

Protective defaults must be balanced against product functionality and user needs. Defaults that are too restrictive may impair legitimate use or drive users to competing products that are less protective. The goal is not maximum restriction but appropriate protection that enables beneficial use while preventing harm.

Risk-based approaches calibrate defaults to the potential for harm. Features that pose minimal risk may not need protective defaults, while high-risk features warrant strong restrictions. Assessment should consider both the probability and severity of potential harm. Location sharing that enables tracking by strangers poses high risk; sharing a user's favorite color poses minimal risk.

User journey design should make it easy to enable features when appropriate while ensuring that enabling decisions are informed. Rather than burying options in complex settings menus, valuable features can be surfaced with clear explanations of what enabling them means. Just-in-time prompts when a user tries to access a restricted feature provide relevant information at the moment of decision.

Age-Based Development Considerations

Developmental appropriateness requires designing products and services that match children's cognitive, social, and emotional capabilities at different ages. A product appropriate for teenagers may be inappropriate for preschoolers, and vice versa. Effective age-appropriate design considers what children can understand, what risks they can recognize, what decisions they can make, and what experiences support healthy development at each stage.

Young children, typically under age 8, have limited understanding of abstract concepts such as privacy, commercial intent, and long-term consequences. They cannot give meaningful consent and should not be presented with complex choices. Design for young children should minimize data collection, eliminate commercial persuasion, and provide simple, safe experiences with minimal user control over consequential settings.

Children ages 8 to 12 develop increasing capability but remain vulnerable to manipulation and may not fully appreciate long-term implications of their choices. They can understand simpler explanations and make some choices but need protection from sophisticated persuasion and potentially harmful content. Design should provide age-appropriate information, meaningful but limited choices, and protection from significant risks.

Teenagers have greater understanding and capability but remain legally minors and may be particularly vulnerable to social pressure, image concerns, and risk-taking. Design for teenagers should respect their developing autonomy while providing guardrails against serious harms. Transparency, meaningful control, and protection against exploitation remain important, but heavy-handed restrictions may be counterproductive.

Cognitive Load and Interface Design

Interface design for children must account for their cognitive capabilities and limitations. Complex navigation, dense text, abstract icons, and multi-step processes that adults handle easily may overwhelm children. Design should reduce cognitive load through simplicity, clarity, and appropriate scaffolding.

Visual design for children should use appropriate imagery, colors, and layouts. Images should represent children's experiences and diversity. Colors should be appropriate to the age group and context. Layouts should be clean and uncluttered, with clear visual hierarchy. Text should use vocabulary, sentence structure, and reading level appropriate to the target age. For non-readers, audio and visual elements should convey information without requiring reading.

Interaction design should match children's motor skills and interaction patterns. Touch targets should be large enough for less precise motor control. Gesture complexity should be appropriate to the age group. Time-sensitive interactions should allow for slower response times. Error recovery should be forgiving of the mistakes children naturally make.

Content and Experience Design

Content presented to children should be appropriate to their developmental stage and should not cause harm. Violent, sexual, frightening, or otherwise inappropriate content should be excluded from children's experiences through both proactive filtering and reactive moderation. Content that promotes unhealthy behaviors, negative self-image, or harmful values should be avoided.

Social features require particular care given the potential for harmful interactions between children and between children and adults. Contact with strangers, public sharing of personal information, exposure to user-generated content, and real-time communication all create risks that must be managed through design choices. Limiting social features to approved contacts, moderating public content, and providing tools for reporting and blocking harmful interactions all contribute to safer social experiences.

Positive developmental outcomes should guide design choices. Products and services for children should support learning, creativity, healthy relationships, physical activity, and other positive outcomes. Engagement mechanisms should not exploit children's vulnerabilities or encourage unhealthy behaviors. The best children's products enrich their users' lives rather than merely capturing their attention.