Media Obligated to Protect Children’s Personal Data

Anna Barseghyan


The Armenian Ministry of Justice’s Personal Data Protection Agency (PDPA) has issued an advisory ruling on publishing children’s personal data.

The move was prompted by a story [AM] titled “Emergency in Yerevan: As a result of rescuers’ proper action, children’s suicide was prevented at a children’s care and protection boarding institution: PHOTO REPORT” published on Shamshyan.com in which the first and last names and the ages of the underage children who “attempted suicide” were reported. Furthermore, the story was accompanied by the children’s photos, in which their faces (close-up) were clearly seen. 

Several news sites then republished the story, copying the children’s personal details verbatim.

According to the Personal Data Protection Agency decision [AM], people working on children’s personal data, including state bodies and the media, are obliged

  • to make public personal data only for a lawful purpose, in a suitable, necessary, and reasonable amount for achieving the objective;
  • when publishing children’s personal data, to demonstrate special caution not to harm children, using means to depersonalize the personal data (change the child’s name, use only their initials, cover the child’s face in a photo, and so on); and
  • to publish children’s personal data only in those exceptional cases when their publication is extremely important to protect the child’s best interest and achieving this objective through depersonalized means is not possible.

The agency expects that media outlets that published children’s personal data or photos will depersonalize or remove them, explaining to their readers the reason for the move.

“This decision is advisory; it has no legal or binding force. We are informing about best international practice. This is the way we get the advisory to the public, to all concerned parties. But we also have decisions that are being made in the scope of administrative proceedings and are obligatory for the parties. But our issue is not to punish or reprimand, but to give advice,” says PDPA head Shushan Doydoyan. 

Earlier, the Media Ethics Observatory (MEO) examined the Shamshyan.com story and concluded that the site had permitted a violation of journalism ethics by publishing a piece on the alleged suicide attempt of two children at a boarding school. According to the MEO judgment, the initial published version of the Shamshyan.com news story violates general principles on publishing news stories on children and runs contrary to the ethical principles of Armenia’s media outlets and journalists.

The MEO urged that when preparing such reports in the future, to be guided by accepted ethical standards, striking a balance between the public’s right to be informed and the protection of children’s rights.

Anna Barseghyan

Updated Mar. 30, 2016: The sentence “According to Doydoyan, if advisory rulings become persistently ignored, it’s possible that a decision to launch administrative proceedings will be made, as a result of which media outlets may be fined” was removed from the article as administrative proceedings do not apply to media outlets.

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