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Using Commonplace with young people (under 13)

Our customers are interested at times in the views of young people. The purpose of this document is to explain the framework for using both the online platform directly and surveys via tablet and Survey Mode or paper forms.

Q: Where do we find the official guidance on gathering data from children?

A: The Information Commissioner’s Office (ICO) has produced specific guidance, available here, on which Commonplace’s policy is based. 

Q: What ages are we talking about?

A: Under 13. From their 13th birthday onwards, a person is deemed to be able to provide informed consent for use of their personal data. 

Q: So if they are under 13, I need consent from the Guardian?

A: Correct. 

Q: Can Commonplace collect these consents?

A: No - there is no provision in the online platform for this - not least because it would be virtually impossible to positively confirm the identities of those claiming to be Guardians.

Q: Is that why the “Age” question in Commonplace does not have a category for “Under 13”?

A: Exactly.

Q: What if we gather the information in face-to-face interviews and only ask the age, and no other personal information (e.g., NOT ask for gender, ethnicity, email address, postcode and any other sensitive information?)

A: This would work, but only if a paper form were used that was specifically designed to eliminate all sensitive personal information except for age. The form needs to make absolutely clear that it is designed in compliance with the ICO Guidance on GDPR and Children (above).

Q: Does that mean that there is no way to collect data from under 13s directly into the online Commonplace interface?

A: Correct, you have to use bespoke redacted forms. 

Q: Do the forms need to be designed specifically for use by children?

A: The ICO requires writing clear privacy notices for children so that they are able to understand what will happen to their personal data, and what rights they have.

Q: I am using bespoke redacted forms; how do I then indicate the age group (Under 13) on the Commonplace platform when I upload the paper forms?

A: Commonplace will add a field to the Survey Mode form that is used to upload paper forms that will not be visible to the public. This field can be used to identify a cohort, in this case that the response was collected from someone under 13. The person entering the data will be advised on that page that they shall not enter any personal information of people less than 13 even if it were available. (Special paper forms shall be used for this age group too that do not include any demographic information).