The Machine-Readable Child: Governance of Emotional AI Used with Canadian Children
Organization
Internet of Things Privacy Forum
Published
2025
Project Leader(s)
Gilad Rosner
Andrew McStay
Summary
This research project investigated the use of Emotional AI with children, and whether the Personal Information Protection and Electronic Documents Act (PIPEDA) is suitable to govern such technology and address its potential privacy and related harms. Emotional AI, in which computers attempt to sense, learn about, and interact with human emotional life, is increasingly being used in education, toys, gaming, and AI companions.
Through interviews with experts, scholars, regulators, child advocates, and Canadian privacy experts, the researchers explored the unique vulnerabilities of children to Emotional AI, including their developing emotional skills, susceptibility to manipulation, and lack of awareness about data collection. The research analyzed PIPEDA in light of other international regulations like the EU’s GDPR and AI Act and the UN Convention on the Rights of the Child. It found that PIPEDA lacks specific protections for children’s data, biometric data, and emotion data, and is currently ill-suited to deter the harms posed by Emotional AI. The report offers a broad range of recommendations to adapt Canadian privacy law and related regulations to address these gaps.
Further, the research generated practical assistance for the makers, sellers, and assessors of child-focused Emotional AI technologies. The report is accompanied by a Privacy Impact Assessment module specifically attuned to these technologies, as well as Canada-focused guidelines for the commercial development, deployment and use of related products and services, and best practices for fairness, accountability, and transparency of emerging Emotional AI systems that will collect the data of Canadian children.
Project deliverables are available in the following language(s):
English
OPC Funded Project
This project received funding support through the Office of the Privacy Commissioner of Canada’s Contributions Program. The opinions expressed in the summary and report(s) are those of the authors and do not necessarily reflect those of the Office of the Privacy Commissioner of Canada. Summaries have been provided by the project authors. Please note that the projects appear in their language of origin.
Contact Information
Gilad Rosner
Internet of Things Privacy Forum
17 St Michaels Road, Winchester, Hampshire SO23 9JE
Email: gilad@iotprivacyforum.org
Telephone: +1 (754) 248-4215
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