CTO Briefing: Why Your Architecture Needs to Account for Minors’ Data — Even If You’re Not in the “Kids Space”

As a CTO or technology leader, you're tasked with building scalable, compliant, and resilient systems. But there’s a growing risk vector that many organizations overlook: the unintentional collection and storage of children’s personal data.

Even if your platform doesn’t serve minors by design, chances are high that they’re still signing up. Globally, one in three internet users is under 18. In the U.S., over 1.7 million children were affected by data breaches in just one year, and most organizations didn’t even know they had minors in their systems.

This is a tech debt issue in the making and it’s one that forward-thinking CTOs should prioritize.

The Engineering Blind Spot: Unknown Minors in Your Ecosystem

Kids are tech-savvy. Eight in ten have admitted to lying about their age to access online services. That means your systems may already be ingesting and storing children’s data— emails, usernames, device identifiers, and behavioral patterns— without the appropriate controls or categorization.

In this new regulatory environment, that’s not just a privacy problem, it’s an architectural flaw with compliance, risk, and reputational consequences.

What’s Changing and Why You Need to Act Now

The COPPA Rule Has Been Updated: This brings new requirements such as a written information security program and regular system audits when handling children’s data.

Global Standards Are Tightening:  Following on from the EU’s GDPR and UK’s Children’s Code several US states have passed Children’s Codes and privacy laws with provisions that cover minors u18. New requirements for age assurance and privacy and safety by design are in place and more are coming.

Security = Compliance + Engineering Rigor: The SEC requires public companies to report on cybersecurity risk management. Mishandling children’s data can create material risk, and put technical leadership under scrutiny.

Questions for CTOs to Ask Their Teams:

• Are we able to confidently identify and categorize data from users under 18?
• Have we built age aware access controls into our architecture?
• Do we have the ability to isolate, minimize, or delete data collected from minors?
• Are our consent workflows and authentication methods designed with age in mind?
• Do we know how our third-party SDKs or vendors handle child user data?

Engineering Action Plan

Audit Your Data Lifecycle – Examine how data flows through your systems, where it's stored, and whether it may include minors.

Embed Age-Aware Architecture – Build smart age gates, consent layers, and data classification tools directly into your infrastructure.

Collaborate Across Functions – Partner with Trust & Safety, Legal, and Privacy teams to ensure compliance is baked into product development.

Prepare for Flexibility by Region – Design systems to dynamically adjust based on jurisdiction, age, and regulatory requirements.

Leverage Specialized Providers – PRIVO offers tools and APIs that simplify age assurance, consent management, and compliance, without slowing down your product roadmap.

Final Thoughts

As a CTO, you are responsible for the systems that process, store, and protect your users' data. In today’s environment, failing to design for the reality of underage users introduces risk— technical, legal, and ethical.

Being proactive about children's data is not just about checking a compliance box, it's about future-proofing your infrastructure, protecting your platform, and doing right by a vulnerable and often invisible user base.

PRIVO can help you assess risk, integrate age aware tech, and stay ahead of evolving regulations.