How to create interfaces that make it easier for children to understand and exercise their rights, and how to empower designers to do so ?

Challenge

For more than 5 years, the CNIL has put the design of privacy at the heart of its priorities, combining research, foresight and practical tools. This is materialised in particular in the review «The Shape of Choices », the platform «Data and Design» set up by the LINC (the CNIL’s digital innovation laboratory) and co-creation workshops conducted since 2019.
In this context, we have been mandated by the CNIL to empower designers on the specific issues of the protection of minors’ personal data, integrating in the work already undertaken by the LINC. The objective? Give designers comprehension keys and action tools to enable them to create interfaces that facilitate the understanding and exercise of their rights by minors.

Why? Children represent about a third of Internet users worldwide while access to information about their rights and how to exercise them is often complex and does not take into account their specificities. They are indeed more vulnerable online than adults and need both protection and empowerment. Information must therefore be pushed to them in order to be fully understood by minors and presented in a “clear and accessible” manner as provided for in the GDPR. It is also a matter of making designers aware of the fact that legal information is not intended to be complex but, conversely, can and must be seamlessly integrated into a user experience of digital interfaces fully designed for underage users.

Process

We started the project with an analysis phase and then carried out a series of focus groups to collect qualitative data on the context of use of minors online and collect their expectations and needs in relation to their rights on their personal data. Divided into 3 age groups, 8-10 years, 11-14 years, 15-17 years, these focus groups allowed us to better understand their practices: they often browse online alone without their parents, have a limited awareness of personal data, their treatment and rights but have a good understanding of the concept of “privacy”. On their data as on all other topics, they want the information “to fall on them”.Thanks to this better understanding of their practices, we were able to start a co-design phase through participatory workshops with the aim of making miners co-researchers and co-designers of interfaces to better translate their point of view. Designers, lawyers and minors were gathered on dedicated sessions, with a separate group for parents. CNIL and LINC observers were present at each stage of these workshops.

Through tailored co-creation activities, we have been able to draft interfaces that are fully integrated into the uses of children by using graphics and UX elements that relate to their browsing experience and elements they already know.
Once the prototypes were developed, we submitted them to an expert audit to ensure that the ergonomics of the interfaces created fully meet the accessibility standards of this audience. We then tested prototypes created in school-based and videocalls user tests and in the form of use scenarios. These tests allowed us to consolidate the dozen of prototypes created initially and then iterate to come up with three final prototypes that collected excellent scores of efficiency, comprehensibility and accessibility among the miners who tested them.

Results

A genuine toolbox that offers keys to understanding and actions to help interface designers address the challenges of children’s privacy protection. Available on the Data and Design platform on the CNIL website, the resources include many methodological tools that are aimed directly at designers.

3 key concepts illustrate fundamental notions of privacy within the interfaces for minors, expressed clearly and simply with good practices and illustrative counter examples.

3 case studies provide designers with examples of implementation of the key concepts with presentations of the prototypes designed in co-creation with minors and which have generated a lot of engagement among children who have tested them.

Methods kits give designers tools for the design and facilitation of user research, co-design and testing workshops with minor participants, based on our research and feedback with proposals for methodologies and exercises.

A popularization article presents the knowledge we have collected during the project on the specificities of minors regarding data protection issues.

3 Youtube tutorials present tips and tools for designers to create interfaces for minor users in a short and engaging format.

We are very satisfied with Amurabi’s services: they listened to our needs, were available and able to show agility and a sense of adaptation that should be emphasized in the context of a health crisis that made the execution of certain services particularly delicate (e.g. the workshops with the children).
Sophie Vuillet-Tavernier
Public & Research Director
CNIL

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