Children's Privacy Review

Children's Privacy Review

Purpose

Organize the facts a reviewing attorney needs to assess whether a product or service attracts, is directed to, or is used by minors, and how it currently handles that population. The skill inventories audience-analysis signals, describes age-gating and parental-consent mechanics as implemented, records data-minimization, default, profiling, and advertising practices as facts, flags school/edtech context, and preserves cross-jurisdiction divergence rather than stating any age threshold as settled. It produces draft legal work product for attorney review — not legal advice.

This skill never concludes that a product "is directed to children," that an age gate or consent flow "is compliant," or that any specific age threshold applies. Those are attorney determinations that depend on jurisdiction, sector, and the totality of the facts. The skill's job is to organize the facts so counsel can make that determination — not to make it.

Use When

• A product, app, game, or online service is being reviewed for whether children's-privacy obligations may apply.
• A product team is designing or has implemented an age gate, age-assurance mechanism, or parental-consent flow and wants the mechanics organized for legal review.
• A launch review, feature review, or marketing-claims review has surfaced signals that minors may be part of the actual or likely audience.
• The organization operates or is evaluating a school-facing or edtech product and needs the school/education context flagged for specialized review.
• A vendor, partner, or internal team raises a concern that underage users may be present despite the stated age gate or terms of service.
• The organization needs a periodic children's-privacy fact review as part of a broader privacy or product-legal audit.

Required Inputs

• A description of the product or service — its functionality, how it is accessed (web, app, in-person, school-issued device), and its stated intended audience.
• Audience-analysis facts — content, subject matter, visual design, marketing channels, user testimonials or reviews, app-store category, influencer or ambassador programs, and any usage or analytics data bearing on the actual or apparent audience. Provide these as facts; do not ask the skill to infer an audience from a bare product name.
• The age-gating mechanics as implemented or designed — whether there is an age screen, self-declaration, neutral age screen, or a technical age-verification or age-estimation method, and how it behaves (e.g., what happens on a "too young" answer).
• The parental-consent flow, if any — how it is triggered, what is collected from the parent, how consent is verified, and what happens if consent is withheld or not obtained.
• Data practices — what personal data is collected from users, what the default settings are (visibility, sharing, notifications, geolocation), and whether profiling, personalization, recommendation systems, or targeted/behavioral advertising are used and whether minors are excluded from them.
• School/edtech context — whether the product is offered directly to consumers, through a school or district, under an operator/school agreement, or as an instructional tool, and who is understood to be the contracting party.
• Optional: any known instance of actual knowledge of underage use inconsistent with the stated audience or age gate — for example, a support ticket, a parent complaint, or internal data suggesting users below the stated minimum age.
• Optional: the practice group's practice-profiles/privacy.md if populated and loaded alongside this skill. If present, use its Standard Positions and Escalation Thresholds to benchmark the review; if absent, proceed without profile benchmarking.