Ms Kathryn Walsh:

There are some really interesting questions there, particularly regarding algorithmic decision-making of the digital marketing to children. Algorithmic decision-making and profiling are key considerations for junk food marketing. It is not just junk food marketing; we also need to consider other harmful products because this food marketing sits at the intersection of multiple harms, infringing on children's privacy and their right to health.

That has been recognised only recently. In this regard, I refer members to paragraphs 41 and 42 of general comment 25 of the Committee on the Rights of the Child, published this year. It relates to the rights of the child in the digital environment. We believe there should be a ban on digital marketing to children. We have the children's commercial communications code of the Broadcasting Authority of Ireland, BAI, and we are aware the BAI will be sitting on the newly-established media commission. The BAI itself has not reviewed the code even though it was supposed to have been reviewed recognising that so much advertising has migrated to online services. I refer to the engaging, interactive type of advertising or user-generated influencer marketing that Dr. Campbell spoke about.

When talking about junk food marketing online, it would be remiss of me not to mention that, only a few weeks ago, the UK reaffirmed its commitment to a ban on online junk food marketing during the Queen's speech. It was thought that it would be rowed back on but Boris Johnson has committed to it. It is going to happen in the UK. In Ireland, the online safety Bill is a key way to achieve that.

On algorithms, it is very hard not to stress the importance of how profiling is used to target children. The Data Protection Commission is developing fundamentals for how to process children's data. It is very explicit in its draft in that there has to be a zero-interference principle when the best interests of the child have to be considered. That is important.

Let me give a statistic from 2017, bearing in mind that we are four years on from then and there has been a global pandemic, meaning children have migrated online for more learning. It is estimated that by the time a child reaches the age of 13, ad-tech companies will have collected over 72 million data points on him or her, that is, 12,000 pieces of data for each hour spent online. That figure is likely to be an underestimation as it excludes many of the trackers currently used by many of the social media giants. They hold so much data on children and use it to profile them and target advertisements. To nip a point in the bud before we go there, it is easy for the companies to prevent their advertisements from being seen by children. It is not just a case of whether the child has said he or she is 18 or 16; the fact is that the companies can infer a person's age based on what they are doing and their browsing history. They can very easily, through due diligence, prevent children from seeing those advertisements.