Children’s health initiative improves privacy protections

The Office of the Data Protection Authority (ODPA) has concluded a compliance initiative to improve children’s privacy rights when using activity tracking wristbands.

Following engagement with the ODPA, an initiative aimed at supporting healthy living for children in the Bailiwick has made positive improvements to its data protection practices, ensuring that children’s privacy rights are protected and respected.

The programme, co-ordinated by Health Improvement Commission (HIC), involves the distribution in schools of wristbands to track children’s activity levels towards improving their well-being.

While the ODPA supported the initiative, there existed opportunities to improve its privacy features including transparency to parents over how personal information was protected and who may have access to the collected data. It was also important to the ODPA that the form of parental consent was opt-in rather than opt-out, as had been originally contemplated.

“By its very nature, children’s personal information is sensitive, and this sensitivity is further heightened by the fact we are dealing with health-related data”, said Data Protection Commissioner Brent Homan. “This was clearly an initiative of high social benefit and we were extremely impressed with the cooperation and evident commitment of the HIC in championing improvements to the programme’s privacy features”

The health programme was powered by tracking wristbands created by UK-based company Moki, who supplies the wristband technology to over 1500 schools across the United Kingdom.

The OPDA engaged with Moki to assess their security safeguards for collected data along with their data protection terms and conditions. The ODPA were satisfied that MOKI’s safeguards, including data anonymisation and encryption were of an elevated level.

The ODPA saw the potential for Moki to improve the transparency of their messaging as to the data they collect and under what circumstances that data would be shared. Moki recognized the merit of our recommendations and agreed to their implementation.

“We are pleased to see Moki’s high safeguard standards for a technology associated with the data of children, and their commitment to transparency improvements that will not only benefit users in Guernsey, but across the UK” said Commissioner Homan.

Note: More information on this initiative can be sourced in the ODPA’s Project Bijou Podcast featuring Alun Williams and Commissioner Homan’s monthly column in the Guernsey Press.