Executive Summary:
This statement reflects the MyData community’s commitment to advancing children’s digital rights in alignment with the EU’s regulatory initiatives. While the EU leads globally in protecting children online, significant gaps remain in turning policy into practice.
The MyData4Children initiative calls for a paradigm shift: children must be seen not as a vulnerable group alone, but as active agents in the construction of their digital futures. Digital systems must be co-designed with their well-being at the centre—protecting their data, empowering their autonomy, and inspiring them to thrive. We emphasise three fundamental and non-negotiable goals:
- Protect children’s privacy and safety by design
- Empower them, their guardians and their circle of trust with knowledge, access, and tools to manage their digital lives
- Inspire children through meaningful, creative digital engagement
The article outlines six MyData principles adapted to children: human-centric control, integration, empowerment, portability, transparency, and interoperability. These principles are illustrated through a fictional case study, showing how children and their guardians could securely manage educational data in real life.
The statement also provides a detailed response to the Commission’s draft guidelines under the Digital Services Act, addressing key areas such as risk, service design, data governance, and ethical innovation. It stresses the need for system-level accountability, stronger safeguards around AI and children’s data, and practical tools for guardians.
The conclusion is clear: protecting children online requires ethical digital transformation, not just legal compliance.
MyData and the MyData4Children Initiative:
We commend the European Commission’s ongoing leadership in advancing children’s rights in the digital age. Initiatives such as GDPR, the Digital Services Act, the Data Act, and the AI Act have established the EU as a global front-runner in protecting young citizens. However, implementing these protections in practice remains a formidable challenge, particularly amid global instability and competing digital priorities.
Children experience the world holistically—blending the physical, digital, social, and emotional. Fragmenting these experiences with isolated or inconsistent digital policies often creates more risks than solutions. What is needed is a unified, child-centred approach to digital transformation in which the ultimate aim is for children to thrive in life, not just in digital realms.
MyData Global is an international non-profit advocating for human-centric data management and governance. We believe individuals should have the right and practical ability to access, control, and benefit from their personal data. This includes children, the members of our society that are perhaps the most vulnerable and least equipped to navigate today’s complex digital terrain.
Our MyData community, composed of experts, entrepreneurs, and thought leaders, believes that children are not merely a user group. They are the immediate future and a powerful vector for building a fairer, more sustainable society. If we truly want systemic change, our digital ecosystems must protect, empower, and inspire children from day one.
The MyData4Children initiative is rooted in this belief. Its goal is to create digital environments that genuinely serve children’s best interests. Building on both UNICEF’s child rights frameworks for digital technologies and MyData principles, the initiative brings together families, educators, policymakers, and technologists to develop practical, rights-respecting solutions.
We emphasise three fundamental and non-negotiable goals:
- Protect children’s privacy and safety by design
- Empower them, their guardians and their circle of trust with knowledge, access, and tools to manage their digital lives
- Inspire children through meaningful, creative digital engagement
Digital systems must be co-designed with children’s needs in mind, considering the full ecosystem around them—including parents, guardians, and other trusted actors. We cannot design for the child in isolation. We call for a systemic change in which children and those raising them do not experience only the challenges and dangers of the digital, but rather, experience fair and ethical digital services which enable children to thrive.
MyData Principles for Children and Youth
We maintain that the critical systemic challenges won’t be solved by only addressing parts of the governance, business and technical current structures. Rather, we need a complete rethinking of how the system works. We need to move towards a human-centric approach: how digitalisation and data serve the human (the child), not the other way around.
The MyData declaration articulates six principles for a human-centric approach to data sharing, in which individuals are both protected and empowered, and value is created for people, businesses and society. These principles can be applied to the context of children’s data, to define a child-centric data model for technological platforms and data governance frameworks. To illustrate this, each of the six MyData principles is presented below, together with an explanation of how it applies to the context of children and youth, and exemplified through the story of a hypothetical family: in the Michel family, 10-year-old Kim and parents Val and Pat are all considered in elaborating a human-centric approach to managing Kim’s educational data.
1. Human-Centric Control
Children, their guardians, and trusted adults should be able to see, understand, and control who uses their data and why. This includes the ability to give or revoke consent meaningfully.
Design must prioritise clarity, agency, and informed choice.
| Illustrating the principle: Kim’s parents are empowered to control and manage the use of education data belonging to Kim until Kim is old enough to do it himself. Kim’s data becomes human-centric when it is available to be used by Kim, Val and Pat in collaboration with their circle of trust (educators, health suppliers, extended family, friends and service providers). |
2. Individual as the Point of Integration
Children should be supported with tools that offer a holistic view of their data—enabling personalisation without compromising safety. Their data should not be unreachable and scattered across disconnected services, but should be securely accessible and under their control.
Design a system where children and their guardians manage their own data.
| Illustrating the principle: Kim is active at school, but also has many hobbies and some extra educational activities, such as speech therapy. Many actors are generating data on Kim (e.g., school records, teachers’ qualitative reports, therapy reports, hobbies badges, achievements diplomas, etc). Kim, Val and Pat have access to all the original data about Kim regardless of the actor generating it. It is Kim’s data, for Kim. |
3. Individual Empowerment
Children must be recognised not as passive users but as agents of their own digital lives. They should have access to tools, skills, and guidance that allow them to transform data into knowledge and make informed decisions.
Design must protect, empower and inspire children through a fair digital model with their wellbeing at the core.
| Illustrating the principle: Kim – firstly through his parents and then by himself – has access and control over all of the scattered data generated about him. Kim, Val and Pat are able to access and manage that data to turn it into actionable information and insights that facilitate Kim’s development. It is not only grades, badges and assessments. It is Kim’s educational history that they use to improve his present and plan his future. |
4. Portability
Children and their guardians must be able to access, download, and reuse their data across services. This must be easy, secure, and not just a legal right, but a functional reality.
Design must enable children and their guardians to use their data, regardless of where it was generated.
| Illustrating the principle: Kim, Val and Pat can reuse the same education data to make education and career decisions and processes easier and faster. When Kim switches schools or applies for higher education, all the educational data is available and can be shared with institutions and actors as Kim sees fit. The data can also be shared with other service providers (e.g., health), with family and with friends. |
5. Transparency and Accountability
Digital service providers and organisations using children’s data must be honest and accountable. The entire value chain of data sources, data holders, and data-using services should be auditable and accountable for how they manage children’s data. Children and their circle of trust should be able to understand how decisions are made using their data, receive alerts on risks, and challenge unfair or opaque processes.
Design must ensure explicit accountability across the data value chain.
| Illustrating the principle: All educational actors (teachers, school boards, ed tech suppliers) explain what education data is created, how it is used, and why. Kim, Val and Pat can raise concerns if they are not comfortable with the handling of Kim’s data. The educational actors are held accountable for any misuse of data, as Kim, Val and Pat can easily revoke access, report misbehaviour, request redressing and demand justice. |
6. Interoperability
Systems must be built to work together seamlessly. Children and families should not be locked into specific services or platforms. Open standards and common practices must be used to ensure data portability and user freedom.
Design of ecosystems must assert and enforce standards and protocols that allow the sharing and consolidation of children’s data by children’s circle of trust.
| Illustrating the principle:Kim, Val and Pat are able to use different services from different education platforms as they see fit. They are not forced to use preselected services available only on one education platform. They are able to share the data from one service or system with another one as there is technical interoperability. Furthermore, they can make use of semantic interoperability to make sense of that data and use it across different contexts. |
A Call to Action
The digital world is evolving rapidly, and children’s data is increasingly being shared, monetized and used to train AI systems without adequate oversight or safeguards. The risks are growing faster than our ability to govern them, and we are missing opportunities to empower and inspire children and their families by strengthening their capacity to manage these risks themselves.
We must prioritise ethical innovation and support structures that enable responsible, scalable solutions—especially for start-ups and SMEs working in the children’s digital space. Protecting children’s data is not just a compliance issue. It’s a moral, social, and developmental imperative.
By aligning digital innovation with child rights from the outset, we not only protect our youngest citizens—we build a better digital society for everyone.
For more information:
- About MyData Global: Please contact Executive Director Christopher Wilson, christopher.wilson@mydata.org
- About MyData4Children: Please contact Co-founder Paula Bello, paula.bello@mydata.org