Can I disclose information about a child to their parents?

As a rule, a child’s custodians have the right to represent their child and act on the child’s behalf. A child’s parents or other people entrusted with the child’s care are the child’s custodians.

However, every child has an independent right to the protection of their personal data. Even though a child’s parent frequently manages the child’s affairs related to the hobby, the child has an independent right to decide on the processing of their personal data.

As a coach, for example, you could be faced with a situation in which one of a child’s parents requests some of the child’s personal data and wants to know whether the child is going to the hobby. This is the first time you have been contacted by this parent, and you notice that their contact details are not stored in the club’s register. What should you do?

• The child’s level of development should be taken into account when evaluating the child’s ability to decide on the processing of their personal data. For example, a child of 7 may not be able to make independent decisions on the processing of their personal data. On the other hand, a 15-year-old could be very capable of managing their own affairs.
• A good rule of thumb is that the older the child, the more likely they are to be able to make decisions regarding the processing of their personal data. For example, if a 15-year-old child prohibits the club from disclosing their contact details to a parent or telling the parent that the child goes to the hobby, disclosing that information to the parent may not be justified.
• If someone asks you for information about a child and you are not sure what to do, contact the club’s administration or another adult working at the club, such as a coach. The adults running the association always have the primary responsibility for the processing of personal data.

You can get more information on the rules for disclosing a child’s data from the following example case