Implementing kids’ privacy protections around the world
This resource provides a case study on a fictional pet simulator mobile app.
Contributors:
Stacy Feuer
CIPP/E, CIPP/US, FIP
Senior Vice President, Privacy Certified
Entertainment Software Rating Board
Timothy Ma
CIPP/E, CIPM
Chief Legal and Privacy Officer
k-ID
Anna Morgan
Partner, Head of Privacy & Data Protection, Ireland
Bird & Bird
Jonathan Tam
CIPP/C, CIPP/US
Tech and AI Partner
Baker McKenzie
Disclaimer: Before you start searching the app stores to download PerfectPetPal, you should know PPP is entirely fictional. The authors prepared this document for a training workshop on children's privacy that took place 14 Nov. 2023 at the IAPP EU Data Protection Congress 2023. After presenting an overview of privacy laws and enforcement matters from jurisdictions around the world, the authors used a case-study approach with workshop participants to apply the different legal frameworks to the fictional pet simulator mobile app. The training concluded with a mini workshop on data protection impact assessments that tied back to the hypothetical pet simulator.
The case study published here does not contain or constitute legal advice and should not be relied on for such purposes. The legal points in this document are high-level, nonexhaustive examples intended only to stimulate discussion. Any similarity between the hypothetical facts in this document and real-life apps, companies or features is coincidental. Neither the IAPP nor the authors of this document accept any liability for any errors or omissions in this document.
Everybody loves pets, right? PerfectPetPal is a recently launched pet simulator mobile app that allows users, known as owners, to create and interact with virtual pets and other owners in new and exciting ways. PPP is wildly popular with people of all ages. The app has more than 100 million monthly active users worldwide, with thousands of new downloads daily. The app is getting lots of buzz — and attention — from journalists, privacy advocates and possibly data privacy regulators. PPP has hired you to assess their privacy practices and provide them with a plan of action.
Contributors:
Stacy Feuer
CIPP/E, CIPP/US, FIP
Senior Vice President, Privacy Certified
Entertainment Software Rating Board
Timothy Ma
CIPP/E, CIPM
Chief Legal and Privacy Officer
k-ID
Anna Morgan
Partner, Head of Privacy & Data Protection, Ireland
Bird & Bird
Jonathan Tam
CIPP/C, CIPP/US
Tech and AI Partner
Baker McKenzie