CRIO pilot

Pilot Project Children’s Rights Infrastructure Online – CRIO (2020-2021)criopilot logo


On paper, the position of children online seems secure. EU legislation describes both the rights and the protection mechanisms to serve children online. In practice though, these rights and protection mechanisms for children are hardly implemented, be it their right to participate in the policymaking process on topics relevant to them online, the protection against being exposed to goods, services, and content items online that are harmful to them or the special protection of their privacy rights online. In effect, this means that children hardly enjoy a special status online and are de facto treated as adults.


A consortium of institutions aims to change the existing situation. Its goal is to create and trial practical solutions to start implementing rights and protection mechanisms for children online.

Six steps

  • Create an effective online age check. The consortium proposes treating age as an end-user attribute that is being validated by reliable database sources. This attribute is to be stored in a wallet on the end-user’s device. In line with privacy by design principles, the attribute is not a date of birth but only the indication whether an end-user is below or above a specific age threshold.
  • Create a mechanism that honors the need for consent by individuals carrying parental responsibilities. Parental consent too is envisioned as an end-user attribute to be stored in an end-user’s wallet.
  • Create child participation mechanisms in policy-making processes on topics that are relevant for their position online. The consortium proposes to create a multinational dialogue platform for children to express themselves and to select representatives to co-create with policymakers.
  • Index and promote effective support mechanisms for children in difficult situations online.
  • Index and promote end-user access to relevant European Union-related content for children.
  • Create an independent institution dedicated to evaluating, monitoring, promoting and drafting rights and protection mechanisms to serve children online.


  • The consortium will base its concrete proposals on the relevant existing legal European and national legal frameworks.
  • The technological basis for the consortium’s proposal is an authentication infrastructure called IRMA: I Reveal My Attributes. The infrastructure was developed by the Foundation Privacy By Design and is regulated by Dutch .nl domain registrar SIDN.


  • Recruit a group of youngsters and parents from milieus that are threatened by social exclusion. This group will participate in Dutch infrastructure field trials and will be communicating their experiences and insights to their peers.
  • Iterative development process of adapting the IRMA infrastructure to the project target group: co-creation of the first field trial based on a feasibility study, evaluation of the first field trial, co-creation of the second field trial, evaluation of the second field trial and co-creation of the final product – a tested and functioning IRMA-based open-source infrastructure that is both sustainable and durable.
  • The field trials are to take place in the Netherlands but are to result in products that are implementable in other European Union Member States too.
  • Create a sustainable and durable dialogue mechanism for youngsters to communicate among themselves, to formulate recommendations and to communicate and co-create with European, national and local policymakers.
  • Draft and publish dissemination material for the general public.
  • Organize two conferences for a more specialized audience.


NB CRIO has been accepted by the European Parliament and the European Commission as a Pilot Project. Its formal title: “Outline and trial an infrastructure dedicated to the implementation of child rights and protection mechanisms in the online domain based on the GDPR and other existing EU legislation relevant for the child within the online domain”.