DPC Guidance Note on Connected Toys

DPC Guidance Note on Connected Toys
DPC Guidance Note on Connected Toys
Recently, the European Consumer Council has contacted Data Protection Authorities around Europe to raise concerns regarding possible data protection issues that might occur when children and parents use toys with microphones and cameras that have an ability to connect to the internet.
These toys, especially dolls, may give the appearance of having a personality and human-like quality that appeals to
children. In some instances, the toys can recognise words and react in certain ways which suggest an emotional
response to what the child says or does. Some toys also connect to apps on smartphones or tablets. This might allow for the collection and recording of “conversations” between the doll and the child, or even act as a “walkietalkie”. For some of these products the voice recordings are shared with other companies, and the toys’ terms and
conditions may allow for your child’s conversations to be used as the basis for targeted advertising.
Any interactions your child might have with these kinds of toys is a potentially sensitive matter.
Parents who are considering buying these kinds of toys this Christmas may wish to take extra care when selecting
any electronic toy that has a camera or voice recording ability, connects to the internet or allows remote connection using a smartphone or tablet app.
The things to look out for include:
What kind of “sensors” the doll comes with – for instance would it record your child’s voice, understand
certain words or phrases, take photographs, or allow video to be captured?
Does the toy have an ability to connect to the internet or to use “Bluetooth” to connect to an app that you
install on your smartphone or tablet?
If there is an app that you can use with the toy and can anyone download and use it? Does a button on the
toy have to be pressed, or does the toy have to be used in a certain way in order for the app to connect to
Can you turn the sensors and network connection on and off, or does the child have to press any buttons in
order for them to work? Is it clear to the child and to you when the sensors are working – for example, do
the toys light up or make a noise when the sensors are activated?
When you read the packaging or manual that comes with the toy, is it clear how these sensors work and
what you can do to control them?
Does the packaging or instructions make it clear if the information is also sent across the internet to the
manufacturer or any other companies or websites?
Does the packaging or instructions say that the information is collected “securely” or using terms like
“https” or “ssl” or “tls”?
Where information is shared with others, are there contact details for these organisations? Do the companies’ websites have privacy policies that allow you understand what they do with the information they collect, how long they keep it for, and allow you to get in touch and ask that the information be erased?
If you have to register on a website to open an account for the toy or the app, does it give you a
“dashboard” or “portal” to see what information is collected and allow you to control it? (Specifically, can
you request that personal data be deleted, stop it being collected or stop it being used for things like advertising/third party sharing?)
If you find that the answers to these questions cannot be found or that you are not happy with them, then our advice to you is to think twice about purchasing the toy. If you are happy to buy the toy for your child, then take care
to ensure that it is working in the way described, and that you are happy with what it is doing, especially when it
shares information with an app or with companies or websites it might connect to.
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