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PCPD Joins Global Network Examining Children's Apps

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Published March 25th, 2026
Detected March 25th, 2026
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Summary

The Privacy Commissioner's Office of Hong Kong joined 26 global privacy authorities in the 2025 Global Privacy Enforcement Network (GPEN) Sweep focused on children's privacy. The exercise examined nearly 900 websites and apps, finding an increase in mandatory data collection and third-party sharing compared to a 2015 sweep, though some platforms showed improved age assurance measures.

What changed

The Privacy Commissioner's Office of Hong Kong participated in the 2025 Global Privacy Enforcement Network (GPEN) Sweep, a collaborative effort with 25 other international privacy enforcement authorities to examine websites and mobile applications used by children. The sweep, which reviewed 876 platforms across various sectors, found concerning trends such as an increase in mandatory personal data collection (names and phone numbers) and a significant rise in platforms sharing children's data with third parties. While some platforms demonstrated improved age assurance measures, many still had easily circumvented safeguards.

This initiative highlights the growing global focus on protecting children's online privacy. Organizations operating platforms used by children should review their data collection, processing, and sharing practices against the findings of this sweep and consider implementing 'privacy by design and by default' principles. The Privacy Commissioner emphasized the vulnerability of children and the need for organizations to prioritize their best interests. While this is a notice of a completed sweep and report, it serves as a strong signal for companies to proactively enhance their privacy protections for minors to avoid potential future enforcement actions or reputational damage.

What to do next

  1. Review data collection, processing, and sharing practices for child-directed or child-popular online services.
  2. Implement 'privacy by design and by default' principles for products and services targeting children.
  3. Ensure age assurance measures are robust and not easily circumvented.

Source document (simplified)

Media Statements

Privacy Commissioner’s Office Joins Global Privacy Enforcement Network in Examining Websites and Apps Used by Children

Date: 25 March 2026

**Privacy Commissioner’s Office Joins Global Privacy Enforcement Network

in Examining Websites and Apps Used by Children**

The Office of the Privacy Commissioner for Personal Data (PCPD) collaborated with 26 privacy enforcement authorities around the world in carrying out the 2025 Global Privacy Enforcement Network (GPEN) Sweep earlier under the theme of “Children’s Privacy”. The exercise examine d almost 900 websites and mobile applications (apps) used by children, and a global joint report was issued today. The participating authorities included those from Australia, Canada, France, Macao SAR China, New Zealand and the United Kingdom.

The purpose behind the GPEN Sweep is to encourage organisations to comply with privacy and data protection legislation, while promoting cooperation between privacy enforcement authorities across the globe.

During the Sweep period between 3 and 7 November 2025, participating authorities examined 876 websites and mobile apps designed specifically for children or popular with them across multiple sectors, including education, gaming, social media, shopping, video streaming, health and fitness, music streaming, and photo editing. The Sweep evaluated these websites and mobile apps based on five indicators, namely (i) age assurance; (ii) collection of children’s data; (iii) protective controls; (iv) account deletion; and (v) inappropriate content and high-risk design features, and compared the results to a similar sweep conducted by the GPEN in 2015.

The Sweep found that some platforms adopted good practices to protect children and their personal data, such as providing notifications advising children not to use their real names or upload images. However, some practices raised concerns about children’s privacy, and that some risks may have increased, compared with 2015. For example, more online services used by children now require users to provide their personal data to access the full functionality of the platform. Compared with 2015, there was an increase in the mandatory collection of certain types of children’s personal data, including names (from 29% to 41%) and phone numbers (from 12% to 18%). Most platforms also indicated in their privacy policies that they may share children’s personal data with third parties (from 51% to 85%).

The Privacy Commissioner for Personal Data (Privacy Commissioner), Ms Ada CHUNG Lai-ling, fully supports closer collaboration of the global privacy protection community to protect the fundamental rights of children. Ms CHUNG said, “As the cognitive abilities of children are still developing, they may not fully understand their personal data privacy rights and are therefore more vulnerable to privacy risks aris ing from less privacy protective settings and design features of websites and mobile apps. Organisations should therefore ensure that the best interests of the child is the primary consideration in the collection, processing and use of children’s data, and adopt privacy by design and by default to ensure that privacy protection measures are embedded from the very beginning of the design and development stages of products and services, with a view to enabling children to use online services safely.”

The salient findings of the Sweep based on five indicators include the following:
- Age assurance: 45% of websites and apps reviewed deployed some form s of age assurance, which represented an increase of 30% from 15% in 2015. For 72% of websites and mobile apps reviewed, age assurance measures could be circumvented , most often where self-declaration was used ;
- *Collection of children’s data:* 96% of websites and mobile apps had privacy policies in place, while only 56% had the personal data collected set to private by default. More than half (59%) of the websites and mobile apps required the collection of an email address to access the full functionality of the platforms, followed by 50% requiring usernames, and 46% requiring geolocation. ***Overall,* there was an increase in the collection of certain types of personal data , such as name s (from 29% to 41%) and phone number s (from 12% to 18%) , compared with 2015 ;**
- *****Protective controls:* 71% of the websites and mobile apps did not provide information about protective controls and privacy protective practices that were tailored to children ;****
- *******Account deletion:* More than one third (36%) of the websites and mobile apps did not provide an accessible way to delete accounts ; and******
- *********Inappropriate content and high-risk design features: Bullying, abusive or hateful content was found in 15% of services, while sexual content appeared in 11% of services. Only 35% of the websites and apps identified as having high-risk data processing and design features for children had privacy* communications*****, such as pop-up messages, directing children to seek permission from their parents to continue using the website or mobile app. *************

The participating authorities encourage websites and mobile apps, particularly those designed for, or popular with, children to adopt child-friendly and privacy-protective practices to contribute to children’s well-being online, including the following:
(i) limit ing the collection of personal data;
(ii) design ing the services to be privacy-protective by design and by default; and
(iii) us ing age assurance mechanisms appropriate to the level of risk on their platforms.

Download the Sweep report (available in English and French):
https://www.privacyenforcement.net/content/2025-global-privacy-sweep-examined-websites-and-apps-used-children

The PCPD participated in a joint operation of the Global Privacy Enforcement Network (GPEN), and a global joint report was issued.
About Global Privacy Enforcement Network (GPEN)
Founded in 2010, the GPEN aims to facilitate cross-border cooperation among privacy enforcement authorities. The PCPD has been a member of the GPEN since 2014 and has continued to be a member of the Executive Committee of the GPEN since 2016.

Source

Analysis generated by AI. Source diff and links are from the original.

Classification

Agency
PCPD
Published
March 25th, 2026
Instrument
Notice
Legal weight
Non-binding
Stage
Final
Change scope
Substantive

Who this affects

Applies to
Consumers Technology companies
Industry sector
5112 Software & Technology 4541 E-Commerce
Activity scope
Data Collection Online Services
Geographic scope
Hong Kong HK

Taxonomy

Primary area
Consumer Protection
Operational domain
Compliance
Compliance frameworks
GDPR CCPA/CPRA
Topics
Data Privacy Children's Privacy

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