Age Verification Providers Association
AVPA
Representing providers of age verification technology.
ID: 490034139503-15
Lobbying Activity
Response to Protection of Minors Guidelines
29 Sept 2024
We are a global trade association representing 30 providers of online age verification and age estimation technology solutions, collectively termed age assurance by the ISOs Committee Draft standard, 27566. We are providing input and evidence on age assurance and verification processes, including standards, technologies and organisational design of an ecosystem to deliver these essential protective measures for children online in an effective and efficient manner. While the Digital Services Act does not include any explicit requirement for digital services to implement age assurance, it is a foundational requirement if providers of online platforms are to put in place appropriate and proportionate measures to ensure a high level of privacy, safety, and security of minors, unless adequate measures are put in place for users of all ages. Please see our response in the attached letter. We would be pleased to facilitate further engagement between the age assurance industry and the Commission to explore these options, and create a pragmatic roadmap that delivers protection for children as quickly as possible, building on what is already working effectively today, and taking an evolutionary approach, rather than risking being dependent on a brand new development of an interim solution with no track record.
Read full responseResponse to Integrated child protection systems
17 Sept 2023
euCONSENT ASBL is a non-profit NGO set up to continue the work of a pilot project initiated by the European Parliament and funded by the European Commission of the same name. The intellectual property from the pilot project was donated to us so we can continue its work to develop interoperable online age verification (including age estimation) and parental consent mechanisms (as required by GDPR Article 8). In addressing child protection, is it critical to consider the online world as well as the Internet. Children spend ever more time on the Internet, and with the advent if virtual reality and the "metaverse", many of the risks to children are shared across both their real and virtual activities. To provide a higher level of protection for children online, it is first necessary to know which users are children. This is achieved through online age verification. Our contribution to that is the creation of a network so each Internet user can re-use an age check (or the contact details of their parent for consent purposes) when they visit new services, without having to repeat the full age verification process. In the absense of such a solution, users would have to repeat a process of using their passport, ID card, reference to authorititative private databases or various methods of age estimatin each time they accessed a online service (or the at least the first time if they then create an account). Most children do not presently have an eIDAS login, and there are no plans to extend access to the EU identity wallet to children 13 and younger. Yet GDPR requires all citizens to prove they are older than 16 (13, 14 or 15 in some Member States) before they can give consent to their personal data being processed without parental consent. And the Commission has appointed a Special group on code of conduct on Age Appropriate Design to develop new rules under the Digital Services Act which will probably require online services to assess the age of their users who are under 16 (13/14/15) as well. The Commission will doubtless consider the risks to children online - often summarised as the 4 Cs of conduct, commerce, contact and content - when developing an integrated system of child protection. We ask that the Commission makes provision to renew its investment in online age verification to develop an effective, user-friendly, standards-base, interoperable system of the sort we have already pilotted with great success across 2,000 adults and children in five European countries. This is a foundational action for any future efforts to protect children online.
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