Contrasting Regulatory Philosophies: Understanding Youth Privacy Through Three Different Approaches
Privacy Enforcement

Contrasting Regulatory Philosophies: Understanding Youth Privacy Through Three Different Approaches

When it comes to youth privacy online, urgency is no longer a debate. The thinktanks are consistently working to figure out how to regulate it. Irrespective of scope, the policymakers aim to strike a balance between protection and participation, between shielding children and empowering them. 

Three approaches illustrate the contrasting ways in which this balance is being attempted: Ontario’s model, shaped by ts Information and Privacy Commissioner (IPC); the U.S. Federal Trade Commission’s latest trajectory, solidified by its “Family Values” messaging; and Nebraska’s recently passed Age-Appropriate Design Code Act, which adds a third dimension by focusing on privacy-by-design principles. While all three approaches aim to safeguard minors, they reflect deeply contrasting regulatory philosophies. A discussion about this contrast can help businesses have a better outlook on youth privacy. 

Why Youth Privacy Demands Nuanced Regulation 

Children online face unique risks: algorithmic profiling, exploitative content, manipulative design, and cyberbullying, to name just a few. However, they also engage deeply with digital life as they learn, create, and express. 

This duality requires a regulatory approach that’s not just protective but deliberate about agency and design as well. And this is where the philosophies begin to diverge. 

Ontario IPC’s Model: Empower, Educate, Engage 

Ontario’s privacy regulator has chosen to treat youth not merely as digital consumers in need of guardrails, but as citizens-in-the-making. The IPC’s model is steeped in engagement, education, and rights awareness. 

Key Components: 

  • Youth Advisory Council: Not a token gesture, but a structural commitment to including minors in shaping policy. 
  • Digital Privacy Charter: A values-driven articulation of what youth digital rights could and should look like. 
  • Education-First Tools: Resources like Privacy Pursuit! and school-ready lesson plans help children understand privacy not as a legal abstraction, but as a lived digital experience. 

The underlying philosophy is clear: equip youth to make better choices, and they will. Children aren’t merely passive users; they are participants with the capacity to grow into informed digital decision-makers. Regulation, in this model, acts more like scaffolding than a wall. 

FTC’s “Family Values” Turn: Protect, Restrict, Enforce 

South of the border, the U.S. Federal Trade Commission is taking a notably different route. At the June 2025 Family Values event, the FTC made clear that its approach is shifting toward sharper enforcement and stronger parental framing. 

Key Components: 

  • COPPA Enforcement: The Children’s Online Privacy Protection Act remains the FTC’s core tool, but its interpretation is becoming more aggressive. 
  • Parental Authority Reframed: The FTC is doubling down on tools that give parents more control regarding content restrictions, activity oversight, and stricter default settings. 
  • Immediate Risk Shielding: This philosophy values safety above autonomy, often removing decision-making power from minors entirely.

In this model, children are understood primarily as dependents, and parents as their digital guardians. Empowerment takes a back seat to protection-first policy, even if it means limiting young users’ engagement or self-determination. 

Nebraska’s Design-Code Approach: Embed, Default, Deflect

Nebraska’s newly signed Age-Appropriate Design Code Act (LB 504) introduces a quieter, more architectural approach to youth privacy. The act doesn’t focus on who makes the decisions (child or parent), but on shaping environments where risky decisions are less likely to arise at all. 

This is regulation by redesign. Instead of reacting to harm or trying to delegate control, Nebraska’s model urges platforms to build safer systems by default—minimizing harm through structural safeguards embedded during development. 

Key Components: 

  • Privacy-by-Design Mandate: Platforms must integrate child-centric privacy protections from the earliest stages of product design.
  • Feature Restrictions: Risky engagement mechanisms like autoplay, infinite scroll, dark patterns, and nighttime notifications are restricted or disabled for minors. 
  • Data Minimization: Collection is limited to only what’s absolutely necessary, and targeted advertising to children is banned outright.
  • Default Safety Settings: Safety isn’t optional—it’s the default. Location tracking, messaging, and visibility settings must favor protection unless actively changed. 

In this model, the system, not the child, parent, or regulator, is the first line of defense. It doesn’t ask children to understand privacy or parents to police it. It asks platforms to prevent harm by removing the trapdoors before anyone falls through. The philosophy here is pragmatic: reduce risk through smarter architecture, not louder oversight. 

Why This Comparison Matters 

This isn’t just a Canada–U.S. comparison anymore. It’s a window into the regulatory crossroads many global jurisdictions now face. For platforms, the question is practical: Are you designing for youth as users with rights, as users under supervision, or as users shielded by design? The answer shapes everything from UX and onboarding to content moderation, data flows, and default safety settings, not just in North America, but anywhere your platform scales. 

For policymakers, this is a question of values and of architecture. What you choose to codify today becomes tomorrow’s precedent. Will your regulatory framework cultivate young people’s digital judgment, safeguard their autonomy through adult controls, or structurally limit exposure through friction and defaults? 

Even if enforcement happens locally, philosophy travels. Ontario’s rights-forward model may ripple outward across Commonwealth and EU-aligned nations. The FTC’s protectionist lens may resonate in regions leaning toward centralized parental control. And Nebraska’s design-code model may quietly influence how platforms build, regardless of who they’re building for. 

When the Youth is at Stake 

This isn’t just a battle over policy, but a battle over defining roles for children in digital spaces. Do we treat them as future-ready citizens with rights worth developing? As dependents to be locked out until they cross some invisible threshold of maturity. Or as users whose safety must be engineered in, long before a single click? The answers to these questions will shape how an entire generation learns to navigate technology. More urgently, they’ll shape how technology is allowed to navigate them. 


Author

Dan Clarke
Dan Clarke
President, Truyo
June 19, 2025

Let Truyo Be Your Guide Towards Safer AI Adoption

Connect with us today