Key Topics Covered

Data Minimization as the First Line of Defense

Compliance Starts with People and Partners

Balancing Regulatory Accountability and Technological Responsibility

In digital learning and assessment environments, data of children requires a higher standard of care than ordinary commercial data. In most privacy frameworks, a child is generally defined as anyone under 18, though legal thresholds may vary by jurisdiction. For assessment organizations, this responsibility is especially important: beyond basic identifiers such as names, student IDs, and dates of birth, they may also process confidential information such as academic results. Even where such data is not legally classified as sensitive, it carries heightened ethical and reputational significance because it concerns children.

Three principles matter most in safeguarding children’s data in assessment platforms: collecting only what is necessary, ensuring strong compliance across people and partners, and balancing regulatory expectations with evolving technologies. Let’s examine them in detail. 

Data Minimization as the First Line of Defense 

The safest way to protect children’s data is not to collect unnecessary or excessive information in the first place. In assessment environments, every additional data point collected creates additional risk. If information is not essential for delivering the assessment, verifying identity, or meeting legal obligations, it should not be collected.

Organizations should regularly question the necessity of each data field: is a full birth date required, or would an age range suffice? Must demographic details be retained after assessment completion? By limiting collection to what is genuinely needed, organizations reduce both compliance burden and security exposure. Just as importantly, data minimization builds trust with parents, schools, and regulators.

Compliance Starts with People and Partners

Children’s data protection depends not only on systems, but also on the people and vendors handling that data. Third-party providers (including cloud platforms, software vendors, and analytics tools) should be carefully vetted and expected to meet recognized information security standards, such as ISO certifications, to ensure strong audited safeguards are in place.

Internally, access to children’s data should be restricted to qualified personnel only. Employees handling student records should receive regular privacy training, and access permissions should follow the principle of least privilege. Where appropriate, organizations may also require background checks for individuals working directly with children's personal information.

Balancing Regulatory Accountability and Technological Responsibility

Protecting children’s data in digital assessment platforms requires organizations to balance three connected responsibilities: meeting regulatory expectations, managing technological risks, and maintaining transparency with families. Assessment providers often operate under oversight from ministries of education, school boards, and public authorities, all of which require clear accountability over how student data is processed.

At the same time, technologies such as AI-driven scoring and learning analytics are reshaping education. While these tools can improve efficiency, they also introduce privacy risks, including excessive profiling, and unnecessary data expansion. When AI is used in children’s data processing, organizations must ensure that such systems remain proportionate, explainable, and subject to human oversight.

Because these technologies affect minors, transparency toward parents and guardians becomes equally important. Families need to understand what data is being collected, how it is used, who can access it, and whether automated systems influence outcomes. Clear privacy notices and open communication are essential to building trust and demonstrating responsible stewardship of children’s information.

Conclusion: What Should Assessment Organizations Do?

Protecting children’s data begins with a simple principle: treat it with greater care because it belongs to a more vulnerable group. For assessment organizations, this means collecting only necessary data, ensuring that all people and partners meet strong security standards, and maintaining transparency with regulators, schools, and families alike.

As education becomes increasingly digital, organizations that protect children’s data responsibly will not only meet compliance expectations but will also earn the trust that makes long-term educational partnerships possible.

About the Author

Jana is an EU-based legal professional specializing in data protection and privacy, with a focus on regulatory compliance. She holds an LL.M. from Stockholm University and is a Certified Information Privacy Professional/Europe (CIPP/E). At Vretta, she supports GDPR compliance and integrates privacy and security principles into the company’s day-to-day operations and digital learning platforms.

Her work centers on making complex legal requirements practical. She enjoys transforming privacy and security into actionable frameworks, helping build a culture where these topics are not just policies, but integral parts of everyday decision-making. 

If you are interested in discussing data protection developments and explore how to strengthen security practices, please feel free to get in touch with Jana Begun at: dpo@vretta.com | LinkedIn

References

1.  GDPR Recital 38: https://gdpr-info.eu/recitals/no-38/

2. United Nations Convention on the Rights of the Child, Article 1: https://www.ohchr.org/en/instruments-mechanisms/instruments/convention-rights-child

3. GDPR Article 5(1)(c): https://gdpr-info.eu/art-5-gdpr/ & European Data Protection Board, Statement 1/2025 on Age Assurance (12 February 2025): https://www.edpb.europa.eu/our-work-tools/our-documents/statements/statement-12025-age-assurance_en 

4. International standards such as ISO/IEC 27001 provide globally recognized benchmarks for information security management and are widely used to demonstrate that vendors maintain independently audited security controls. ISO/IEC 27001 Overview: https://www.iso.org/isoiec-27001-information-security.html.

5. GDPR Article 32: https://gdpr-info.eu/art-32-gdpr/.

6. OECD AI Principles: https://oecd.ai/en/ai-principles

7. GDPR Article 5(1)(a): https://gdpr-info.eu/art-5-gdpr/