Ms Alex Cooney:

I hope I cover all the bases. We believe the digital age of consent should be 13. If it is raised to 16, it will make children in fact more vulnerable, even if at face value it seems it will protect their data. I mentioned that 72% of the children to whom we speak, the vast majority of whom - 94% or 96%, I think - are under 13, are already accessing these services, and many of them are doing so with parental consent. Therefore, we really need to consider parental consent and what informed parental consent looks like. If we raise the digital age of consent to 16, we will simply have more children lying about their ages to get online and not being afforded the basic safeguards that are available for children who are 13 and older, 13 being, in theory, the age at which they are allowed to access these services. There are measures in the general regulation that will address children's data, and that is positive. It is the first time this has been done. However, the digital age of consent, which has captured everyone's interest in recent weeks, is not really the solution. It will not stop children accessing the services, it will not protect their data, it will mean more children lying about their ages and it will not provide the safeguards needed. It would be great to see the data of all children under the age of 18 protected regardless. That should just be the rule: if they are under 18, one is not allowed to collect data from them or advertise to them. The solution should not be so connected to the digital age of consent. Our view is that the digital age of consent should be 13. We feel that will keep children safer. What we want is proper parental engagement and parents making informed decisions as to when their children are ready to access these services, own devices and so on.

Regarding online safety in the curriculum, we absolutely need to address these issues at school and in the curriculum in an age and stage-appropriate way. This needs to happen at primary school as well as secondary school. The problem is that there is a big gap between what children are exposed to online from a young age and what they are learning about through those sources and the reality. Parents at home and in schools offer the opportunity to explore these issues in a safe way.