Your standard Data Protection Impact Assessment (DPIA) template wasn't written with children in mind. It asks about data minimization and appropriate technical and organisational measures, but it doesn't address the developmental differences between an eight-year-old and a sixteen-year-old. It doesn't force you to document why behavioral profiling is necessary when your users can't meaningfully consent to it.
Regulators are moving away from treating children's data protection as a question of consent. They're evaluating how you design and operate services. That means your DPIA process needs to reflect child-specific risks before you launch, not after a supervisory authority asks why you didn't consider them.
This template gives you a structured framework for conducting a child-specific DPIA that addresses the design and operational expectations now emerging across jurisdictions: privacy by design, age-appropriate design, restrictions on behavioral profiling, and transparency adapted to developmental capacity.
Purpose of This Template
This DPIA template is designed for controllers who process personal data of children through digital services. It extends the standard DPIA required under Article 35 GDPR by incorporating child-specific risk factors that general templates overlook.
Use this when you're:
- Launching a new service that children can access
- Adding features that process children's behavioral data
- Implementing profiling or automated decision-making where children are involved
- Conducting periodic reviews of existing services used by children
The template focuses on the design and operational standards that regulators expect, not just consent mechanisms. It forces you to document decisions about data collection, interface design, default settings, and retention before those decisions become compliance problems.
Prerequisites
Before you start, you need:
Clear scope definition. Document which age groups will use your service. "Under 18" isn't specific enough. A service for 6-to-9-year-olds requires different safeguards than one for 14-to-17-year-olds.
Processing inventory. List every data point you collect, why you collect it, and how long you keep it. Include behavioral data: clicks, time spent, interaction patterns, location data, device identifiers.
Feature documentation. Identify any features involving profiling, personalization, social interaction, content recommendation, or advertising. These require specific justification in a child context.
Design authority. You need input from product teams who can actually change interface design, default settings, and feature behavior. A DPIA that documents risks without the authority to address them is just paperwork.
The Template
SECTION 1: Service Description and Age Groups
Service name:
Primary purpose:
Age range of intended users:
Is age verification implemented? If yes, describe method:
Can children under 13 access this service?
SECTION 2: Data Collection Assessment
For each data element you collect:
| Data Element | Purpose | Lawful Basis | Is this strictly necessary? | Could you achieve the purpose without this data? | Default setting (collected by default Y/N) |
|---|---|---|---|---|---|
SECTION 3: Profiling and Behavioral Processing
Does your service:
- Build user profiles based on behavior? (Y/N)
- Use behavioral data for content recommendation? (Y/N)
- Serve targeted advertising based on user activity? (Y/N)
- Make automated decisions that affect what children see or can do? (Y/N)
For each "yes" answer:
- Document the specific processing activity
- Explain why this is necessary for the service to function
- Describe what happens if you disable this processing
- Identify whether this creates a risk of manipulation or inappropriate content exposure
SECTION 4: Privacy by Design Evaluation
For each major feature, document:
Data minimization:
What's the minimum data required for this feature to work?
What data are you collecting beyond that minimum?
Justify each additional data point or remove it.
Default settings:
Is the privacy-protective option the default? (Y/N)
If no, explain why and document the risk.
Retention:
How long do you keep behavioral data?
Why is this retention period necessary?
Can you achieve your purpose with a shorter period?
SECTION 5: Age-Appropriate Design
Interface assessment:
- Is privacy information written for the age group using this service? (Y/N)
- Have you tested comprehension with actual users in this age range? (Y/N)
- Are privacy controls easy to find and use without adult help? (Y/N)
- Do prompts and notifications use manipulative design patterns? (Y/N)
For any "no" or "yes" on manipulative patterns, document the specific issue and remediation plan.
SECTION 6: Risk Identification
Identify specific risks to children:
| Risk | Likelihood (Low/Medium/High) | Impact (Low/Medium/High) | Mitigation Measure | Residual Risk |
|---|---|---|---|---|
| Behavioral profiling creates filter bubble | ||||
| Excessive data collection enables future misuse | ||||
| Interface design pressures sharing | ||||
| Inadequate age verification allows younger children access | ||||
| Long retention period creates future identification risk |
Add rows for risks specific to your service.
SECTION 7: Consultation
Document who you consulted:
- Data protection officer: (name, date)
- Child development expert: (name, date, key recommendations)
- Product team: (names, date, design changes agreed)
- Legal: (name, date, compliance sign-off)
SECTION 8: Approval and Review
Completed by:
Review date:
Next review scheduled:
Approved by:
How to Customize It
Age-specific language. Section 5 asks whether privacy information is age-appropriate. For younger children (under 10), this might mean video explanations or icon-based controls. For teenagers, it means direct language about what happens to their data without corporate euphemisms.
Jurisdiction-specific requirements. If you operate in California, add a section documenting compliance with the California Age-Appropriate Design Code Act. If you're in the UK, reference the Age Appropriate Design Code. The core structure remains the same; you're adding jurisdiction-specific checkpoints.
Service-specific risks. Section 6 includes common risks, but you need to add risks specific to your service type. A gaming platform faces different risks than an educational app. Consider: Can children contact strangers? Does your algorithm recommend progressively extreme content? Can behavioral data be used to infer sensitive characteristics?
Profiling justification. If Section 3 reveals you're doing behavioral profiling, you need a robust justification. "Improves user experience" isn't sufficient. Document the specific harm that occurs without profiling, and explain why less invasive methods won't work. If you can't articulate this clearly, you probably shouldn't be profiling children.
Validation Steps
Internal review. Before you consider this DPIA complete, your data protection officer must review it. If you don't have a DPO, this is a strong signal you need one for this processing activity.
Product team sign-off. Every mitigation measure in Section 6 must have an owner and a timeline. If product teams haven't committed to implementing the changes, your DPIA documents risk without managing it.
Comprehension testing. Section 5 asks whether children understand your privacy information. Test this. Show your privacy notice to children in your target age range and ask them to explain what happens to their data. If they can't, rewrite it.
Supervisory authority consultation. Article 36 GDPR requires you to consult your supervisory authority before processing if your DPIA reveals high risk that you cannot adequately mitigate. Don't skip this step because it's uncomfortable. It's significantly less uncomfortable than an enforcement action.
Periodic review. Set a review date in Section 8 and actually conduct it. Children's services evolve quickly. New features, new data uses, and new risks require updated assessment. An annual review cycle is minimum; quarterly is better for services that ship features frequently.
This template won't make hard decisions for you. It will force you to document them, justify them, and own them. Regulators are evaluating how you design and operate services for children, and this DPIA gives you the structure to demonstrate you've done that work rigorously.
