Article 8·medium·Component: Chapter II: PrinciplesWhat this control requires
Ensures lawful processing of a child's personal data for information society services, requiring parental consent for children under 16, with verification efforts. This control addresses Application (UI).
In plain English
Ensures lawful processing of a child's personal data for information society services, requiring parental consent for children under 16, with verification efforts. In practice, this means you can prove you principles consent-level controls on a defined cadence.
Why it matters
GDPR administrative fines reach the greater of €20 million or 4% of global annual turnover. The European Data Protection Board (EDPB) coordinates supervisory-authority enforcement across the EU/EEA, and DPAs publish enforcement decisions citing specific Articles.
What an auditor looks for
A DPA or privacy auditor expects: a Records of Processing Activities (RoPA) entry, a documented lawful basis, evidence the Article's data-subject right is operationalised end-to-end, a named DPO contact (where required), and Article 30 records that match what the front-end actually does.
Within Chapter II: Principles, the assessor will trace your implementation back to the catalogue reference (Article Article 8) and look for objective evidence on the latest two assessment cycles.
How to implement
Policy Management
Docs. Keep each policy in version-controlled Markdown alongside the code that implements it; ship a signed PDF snapshot at each annual review and link the SHA into the SoA.
Operational checklist
- Principles. Document the trigger, the owner and the cadence.
- Conditions. Document the trigger, the owner and the cadence.
- Information. Document the trigger, the owner and the cadence.
- Data. Document the trigger, the owner and the cadence.
- Scope: consent, information.
Evidence to collect
- Policy Document. A signed and version-controlled policy / standard / procedure document.
- Infra Scan. Continuous infrastructure-posture telemetry — AWS Config, Azure Policy compliance, GCP Organisation Policy, Wiz / Prisma findings.
Signed policy or standard documents the safeguard. Focus: Conditions applicable to child's consent in relation to information society services.
Common pitfalls
- Policies that no engineer has read; the version in Confluence drifts from the version that's actually being enforced.
How it maps to other frameworks
Computed from shared tags, control component and key-operation subjects — handy when you are reconciling controls across an audit.
- India DPDP Act 2023 DS-005 — Consent Withdrawal Mechanism
- ISO/IEC 27701:2025 A.1.2.5 — Obtain & record consent
- ISO/IEC 27001:2022 A.5.13 — Labelling of information
- SOC 2 (2017 TSC) P3.2 — Consent Management for Personal Information Collection
- NIST SP 800-53 Rev. 5 PT-4 — Consent
Related controls in GDPR
- Article Article 6 — Lawfulness of processing
- Article Article 7 — Conditions for consent
- Article Article 9 — Processing of special categories of personal data
- Article Article 11 — Processing which does not require identification
- Article Article 4 — Definitions
- Article Article 10 — Processing of personal data relating to criminal convictions and offences
References
- European Union — GDPR
- Catalogue identifier:
Article Article 8
Topics: governance riskpolicy managementprivacy management