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On
February
16,
2023,
the
Centre
for
Information
Policy
Leadership
(“CIPL”)
at
Hunton
Andrews
Kurth
LLP
held
a
virtual
roundtable
to
discuss
the
role
of
age
assurance
and
age
verification
tools
as
part
of
its
Children’s
Data
Privacy
Project.
Representatives
from
CIPL
member
companies,
data
protection
authorities,
civil
society
and
experts
exchanged
views
on
the
effectiveness
of
different
methodologies
and
emerging
best
practices
to
shield
minors
from
harmful
or
inappropriate
content.
Key
Takeaways
from
the
Discussions:
1.
When
it
comes
to
age
assurance,
the
methodology
and
timing
of
deployment
depend
on
the
nature
of
the
service
and
the
risk
to
children,
including
likelihood
and
severity.
The
features
and
designs
specific
to
a
given
service
and
the
level
of
potential
risks
to
children,
including
the
likelihood
and
severity
of
such
risks,
are
critical
factors
in
determining
whether
age
assurance
is
required,
which
methodology
is
most
appropriate
and
how
and
when
it
should
be
deployed.
2.
There
is
no
silver
bullet.
No
methodology
is
better
than
another,
but
one
could
be
more
appropriate
and
effective
for
the
specific
use
case.
Each
age
assurance
methodology
has
unique
strengths
and
weaknesses.
To
select
the
most
suitable
one,
an
evaluation
of
its
effectiveness
in
mitigating
and
addressing
specific
risks
and
harms
is
necessary.
Regulatory
expectations
must
take
into
account
the
practical
and
technical
feasibility
of
different
methods
and
their
impact
on
user
experience.
3.
To
perform
proper
risk
assessments,
organizations
need
guidance
on
adequate
age
assurance
criteria
and
risk
taxonomy.
Existing
regulatory
guidelines
and
continuous
regulatory
engagement
are
useful
tools.
However,
appropriate
risk
assessments
are
still
a
challenge
for
companies
looking
to
design
and
implement
repeatable
and
systematic
processes.
4.
To
be
effective,
the
design
and
deployment
of
age
assurance
tools
should
continuously
research
and
consider
children’s
behavior
and
motivation.
Children
may
falsify
their
age
in
order
to
access
online
services.
Understanding
the
motivations
behind
this
behavior
can
support
better
design,
transparency
and
trust,
ultimately
leading
to
a
more
successful
and
appropriate
approach
to
age
assurance.
5.
Age
assurance
is
only
one
of
the
tools
available
to
keep
children
safe
online;
it
cannot
be
used
in
isolation.
Organizations
cannot
rely
on
age
assurance
alone.
To
ensure
compliance
with
various
legal
requirements,
organizations
will
need
to
employ
a
multifaceted
approach
that
includes
for
instance
privacy
and
safety
by
design
and
default,
appropriate
user-centric
transparency,
content
moderation,
personalization
of
content,
parental
consent
or
family-specific
controls
and
age-appropriate
services.
The
best
interest
of
the
child
must
be
a
key
consideration.
6.
Constructive
engagement
and
information
sharing
are
essential
for
developing
standards
and
certifications
for
age
verification
and
assurance.
Many
organizations,
especially
larger
ones,
have
made
significant
investments
and
commitments
to
develop
best
practices
for
age
verification
and
assurance.
However,
as
research
and
knowledge
evolve,
it
is
imperative
that
all
stakeholders
(industry,
policymakers,
regulators
and
civil
society)
continue
to
engage
in
ongoing
dialogue
regarding
expectations
and
progress.
Read
the
full
takeaways
summary
here.
Future
CIPL
roundtables
on
the
Children’s
Data
Privacy
Project
will
address
the
risk-based
approach
to
the
protection
of
children
online,
transparency,
consent
and
other
legal
grounds
for
processing
and
personalization.
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