PRIVO Blog

CISO Alert: A Call to Action for the C-Suite - Even If Your Company Isn't in "The Kids Biz"

Written by PRIVO | 5/7/25 5:33 PM

Even if engaging with minors is not one of your company’s objectives, as a CISO or Information Security Executive, you're already on the front lines of one of the fastest-evolving areas of risk: the privacy and data protection of minors.

Worldwide, one in three internet users is under the age of 18. And with 80% of children admitting to lying about their age to access digital services, your systems likely already hold minors’ data—whether you meant to collect it or not.

As regulations rapidly expand to address this reality, the stakes are rising for security and privacy leaders. Ignorance is no longer a defense. In today’s environment, failing to recognize and handle children’s data properly is a compliance risk, a reputational risk, and ultimately a security risk.

Children’s Data: A Growing Attack Surface

In 2022, over 1.7 million children were victims of data breaches in the U.S. alone—roughly one in every 43 kids. And children’s identities are especially vulnerable. Unlike adults, they don’t regularly check credit reports or have a financial history, making stolen identities ripe for long-term fraud.

As a CISO/ Information Security Executive, you are tasked with the weighty responsibility to protect the organization from vulnerabilities and threats. Minors’ data, especially when collected unintentionally, is a blind spot that bad actors can exploit—and regulators are beginning to crack down on it.

Why Now?

Children’s privacy is rapidly becoming a frontline issue for Information Security Executives —even at companies that don’t directly target young audiences. In just the past year, regulatory momentum has accelerated across the globe:

  • Increased Accountability: 
    The SEC now requires public companies to disclose material cybersecurity incidents and report on their cybersecurity risk management practices. This shift has placed CISOs/ Information Security Executives  under intense scrutiny—where failure or misleading disclosures could result in personal liability.

  • Rising Fines:
    Global penalties for violations of children's privacy laws have surpassed $1.3 billion, underscoring regulators' willingness to act.

  • COPPA Amendments Soon to be Enforced:
    The updated U.S. children’s privacy law, COPPA, is mandating a written information security program, including regular testing and monitoring, to protect children’s personal data.
  • Expanding State Laws:
    A growing number of U.S. states are passing privacy laws that raise the age of protection and extend obligations to general audience sites—whether or not they knowingly collect data from minors.
  • Global Standards Are Tightening:
    The UK’s Children’s Code, the EU’s GDPR, and similar international frameworks now require age-appropriate design, data minimization, and clear accountability when minors are involved.

And this is just the beginning. Enforcement is ramping up—making it critical for security and privacy leaders to act now.

You May Not Target Kids, But They May Be in Your Systems

If your company collects emails, phone numbers, device identifiers, usernames, or birthdates—there’s a chance a portion of your user base is under 18, whether or not your services were designed for them. Without strong age assurance, parental consent mechanisms, and data categorization, you may be holding sensitive data that should be subject to stricter controls.

Ask yourself:

  • Do we know the age of our users with any degree of certainty?

  • Have we implemented a smart, jurisdiction-aware age gate?

  • Are we flagging and segregating accounts tied to underage users?

  • Are our policies and access controls adjusted for minors' data?

  • Can we confidently say we’re not storing or using children’s data in violation of COPPA, GDPR, or other laws?

Actionable Steps for Security Leaders

  1. Audit your data – Identify what data is being collected, where it’s stored, and whether it includes or could include minors.

  2. Implement age assurance – Don’t rely on self-declaration alone. Look into tools that can verify age or flag underage activity.

  3. Involve cross-functional teams – Partner with legal, marketing, and product to align security practices with privacy expectations.

  4. Establish a child data policy – Even if you’re not targeting kids, you need a clear protocol if a child enters your ecosystem.

  5. Partner with experts – Third parties like PRIVO can help you assess risk, implement protections, and certify compliance.

Final Thoughts

The bottom line? Minors are already accessing your digital services. The question is whether you’re prepared for the risks that come with it.

As a CISO/ Information Security Executive, you’re uniquely positioned to champion stronger controls, prevent unauthorized data collection, and help your organization avoid becoming the next cautionary tale in a headline. Children's privacy isn’t just a compliance checkbox—it's a core component of a robust, forward-looking security strategy.

Contact PRIVO for expert guidance and to see a demo of our easy to implement compliant age aware solutions.