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Data privacy on new current account for a child
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Name the bank please - someone on here will know the procedures for various banks.0
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According to the ICO the age of consent on digital privacy is 13 not 16 https://ico.org.uk/for-organisations/guide-to-data-protection/key-data-protection-themes/children/
If you look at the further guidance on https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/children-and-the-gdpr/what-rights-do-children-have/ life gets a lot more complicated ...How does this work in practice?
An adult with parental responsibility may seek to exercise any of the child’s rights on their behalf.
If you are satisfied that the child is not competent, and that the person who has approached you holds parental responsibility for the child, then it is usually appropriate to let the holder of parental responsibility exercise the child’s rights on their behalf. The exception to this is if, in the specific circumstances of the case, you have evidence that this is not in the best interests of the child.
If you are confident that the child can understand their rights, then you should usually respond directly to the child. You may, however, allow the parent to exercise the child’s rights on their behalf if the child authorises this, or again if it is evident that this is in the best interests of the child.
So whereas initial consent to processing of data as a set age limit subsequent to that it is for the organisation to determin if the child is competent in understanding the situation... if they are then the child has to give consent, if they arent then parents can access without consent.
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