GDPR-K GDPR Art. 37 — Data Protection Officer (children's data context)
Organisations processing children's personal data at scale should designate a Data Protection Officer to oversee children's data processing activities
Where this comes from
Provision: GDPR Art. 37 — Data Protection Officer (children's data context)
Instrument: General Data Protection Regulation (EU) 2016/679
Citation: Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, Article 37(1); Article 29 Working Party Guidelines on Data Protection Officers (WP 243 rev.01); EDPB Guidelines 07/2020 on the concepts of controller and processor
Text version: Regulation (EU) 2016/679 (GDPR), OJ L 119, 4.5.2016, consolidated
Who it applies to
It applies when all of these are true:
- Service is likely to be accessed by children under 18
What engineering work it implies
Sample acceptance criteria Landfall generates for this obligation:
- Implementation or documented process meets the reviewed acceptance criteria; identify the tested version and deployment status separately
- Configure defaults from the assessed source and purpose; do not enable data collection or processing merely because this task exists
- Validate behavior for the assessed actors and use cases, including applicable guest or administrator paths
- UI clearly communicates what the feature does to users
- API returns appropriate error codes when feature blocks an action
Questions people ask
- Does GDPR-K GDPR Art. 37 — Data Protection Officer (children's data context) apply to my service?
- It applies when Service is likely to be accessed by children under 18.
- From when does this apply?
- GDPR-K GDPR Art. 37 — Data Protection Officer (children's data context) applies from 25 May 2018. Its current status is: in force.
Find out whether this one lands on you
Landfall's pre-scan answers the applicability question above for your product in minutes, then turns every obligation that applies into traceable engineering tickets with a citation chain your auditors can follow.
Not legal advice. Landfall maps regulatory obligations to engineering work for planning purposes. Its verdicts are not legal advice and create no attorney-client relationship — verify with qualified counsel before relying on them.