Reframing child protection online: Privacy protects, protection preserves privacy

Protecting children from abuse and safeguarding their privacy are not competing goals, they are two sides of the same child-protection duty. 

The public debate around children’s rights online and the proposed EU Regulation to Prevent and Combat Child Sexual Abuse is often erroneously framed as a conflicting choice between child safety and privacy. However, this narrative does not align with the human rights framework, which recognises that children’s rights are interconnected and that determining their best interests requires a careful balancing of those rights. Under the UN Convention on the Rights of the Child (UNCRC), children have the right to be protected from all types of violence and exploitation, and they also have rights to privacy. States are bound to respect and uphold these rights in the digital environment as well, as highlighted in General Comment No. 25. In this context, privacy and child protection are closely interlinked: safeguarding children’s privacy is not at odds with keeping them safe; rather, it is an essential component of their protection, both online and offline.

While offering opportunities, the online environment exposes children to increasingly serious risks, including sexual abuse, exploitation and grooming. To respond to this child sexual abuse crisis, the proposed EU Regulation to Prevent and Combat Child Sexual Abuse aims at strengthening child safety online and preventing these crimes, by setting a legal framework for platforms to detect, report and remove child sexual abuse material on their services. The Regulation’s objective is to prevent and address sexual abuse offences against children in a proportionate way, recognising that child protection and the respect of all fundamental rights, among which the right to privacy must go hand in hand, rather than framing safety and privacy as opposing interests. To ensure this, the proposal includes many safeguards, such as risk-based assessments, targeted measures for platforms, judicial oversight, and checks by national authorities, including data protection authorities. Hence, detection would be targeted, time-limited, carried out with “privacy-preserving” tools and authorised on a case-by-case basis, based on necessity and proportionality. 

While recognising and protecting everyone’s right to privacy, it is crucial to remember that privacy is also a core component of children’s safety and wellbeing. The continued circulation of abuse images online is a violation of their dignity, safety and privacy. For victims, abuse often involves the most extreme intrusion into a child’s bodily and intimate life, and when images or videos are created, shared or stored, that violation can continue for years through repeated viewing and circulation online. Moreover, private and secure communication can be essential for seeking help, reporting abuse and contacting helplines, especially for children who face violence.

Emerging technologies, including artificial intelligence, make the link between privacy and safety even more critical. Children’s personal data and images can be misused, for instance to create or manipulate sexualised images. In the first six months of 2025 AI generated child sexual abuse material increased by  400%. Eurochild members confirm these rising trends, which significantly increase the risk of exploitation and long-term psychological harm for children.

Protecting children online is not a choice between privacy and safety. Privacy must be respected for all users, but only by re-centring children’s best interests and recognising privacy as a key element of prevention and child protection, it is possible to keep children safe, online and offline.