GPD submits response to DSIT national consultation on age-based online restrictions

Today, GPD submitted its response to the UK Department for Science, Technology and Industry (DSIT) consultation: Growing up in the online world. The consultation spans questions related to age-based restrictions on access to social media, restrictions on specific functionalities or design features, and curfew restrictions.

In our response, GPD calls for the government to prioritise platform design obligations over access-based restrictions as the primary mechanism for keeping children safe online. A higher minimum age for social media would not eliminate the harms children face online, including exposure to harmful algorithmic content, manipulative design, and commercial exploitation of their data. These harms originate in how platforms are designed and monetised rather than in the absence of age gates. 

In contrast, enforcing a minimum age requirement across certain services would create disproportionate privacy and surveillance risks at population scale. Existing age verification methods pose distinct and compounding harms, ranging from methods that exclude certain population groups by design; age estimation systems that produce discriminatory and inaccurate outcomes; or approaches that risk cementing the dominance of a small number of intermediaries. Restricting access to online spaces in a blanket manner also constitutes a disproportionate restriction of children’s and adults rights to freedom of expression, freedom of association and other rights. 

GPD is particularly concerned by proposals to restrict privacy-preserving functionalities, such as end-to-end encryption (E2EE) and Virtual Private Networks (VPNs). Applying age assurance requirements to these services defeats their very purpose: to provide essential privacy and security benefits. These are benefits that are directly experienced by young people who make use of VPNs and encrypted platforms for legitimate purposes: to shield themselves from the breach, extraction and monetisation of their personal data. We call on the government to exempt these essential functionalities from access-based restrictions.

If the government decides to pursue age-based access restrictions on certain online services, GPD urges that additional work and multistakeholder dialogue is needed to address privacy, security, and human rights issues prior to wide deployment.