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New guidance on children’s rights in the digital environment must be acted upon by the digital health community

Louise Holly
April 27, 2021

Last month, the UN Committee on the Rights of the Child adopted the eagerly awaited General Comment 25 on ‘children’s rights in relation to the digital environment’. General comments are authoritative documents that help states and other actors interpret human rights treaties in different contexts. The UN Convention on the Rights of the Child (UNCRC) is the world’s most ratified human rights treaty and, with this new general comment, is the first to fully embed children’s rights into the digital domain.

Guidance on children’s rights and digital health

General Comment 25 underscores the potential for digital technologies to support children’s right to health. It encourages governments to use digital tools to strengthen health systems, promote healthy lifestyles, and increase children’s access to health services and information, including in times of public emergency or crisis. Children consulted in the development of the general comment said they appreciated the ability to find information and support online relating to health and well-being. They requested digital health services that are free, confidential, age-appropriate, and non-discriminatory, particularly to support their mental health and sexual and reproductive health.

The general comment cautions, however, that digital health services should not replace, but rather supplement and improve, in-person provision of health services to children. Furthermore, the adoption of digital products and services should not create or increase health inequities.

Digital health actors are reminded that the full spectrum of children’s rights must be considered in the regulation, design, management, and use of digital health technologies and services. Looking at the right to health in isolation is insufficient.

Digital technologies and the collection of children’s data should enhance a child’s health but not at the expense of other rights, such as their right to privacy or to have their views heard in matters that affect them.

The general comment offers a critical reminder that the wider digital environment can have positive and negative impacts on children’s health and well-being, which in turn can impact their health status into adulthood. For example, children’s use of digital technologies can improve their access to quality healthcare and, at the same time, expose them to health misinformation, marketing of unhealthy products, and a range of other harms to their physical and mental health. The health sector needs to pay attention to the ways in which children’s engagement with the digital environment might strengthen or undermine efforts to improve children’s current and future health and well-being.

Translating the general comment into action

Within the general comment, governments can obtain guidance on the range of legislative, regulatory, and other measures required to prioritise the best interests of every child in the design, implementation, and evaluation of digital health tools and approaches. This is not just a document for governments though: other actors in the digital health ecosystem should also work to translate the UNCRC and recommendations from the General Comment 25 into action. Non-governmental actors, particularly businesses involved in the digital environment and the processing of children’s data, also have responsibilities to account for the rights of children in their operations.

To date, technical and normative guidance on digital health has overlooked children’s rights. The adoption of General Comment 25 presents an opportunity for this deficiency to be rectified. International organisations such as the World Health Organization (WHO) and International Telecommunication Union (ITU) have influential roles to play in encouraging a child-rights approach to be embedded in the policies and practices of governments and other digital health partners. Both WHO and ITU have welcomed the general comment. They should now take steps to update existing guidance such as the National eHealth Strategy Toolkit, and support government ministries and partners to put children’s rights at the centre of their strategic approaches to digital health and other digital transformations.

Everyone involved in digital health, from policymakers to technology developers to health professionals using digital tools to care for children, must act now to implement the recommendations in General Comment 25. All parties should put measures in place to assess the potential impacts of digital health tools and services - positive and negative - on children’s rights. They should also increase opportunities for children to be agents of change and to shape the design of digital technologies, as well as the policies that govern them.

The Commission’s work will continue to be guided by child rights and human rights principles. Through our newly launched GHFutures2030 Youth Network, we’re inviting young people to co-create and co-lead future digital transformations that can support the health and well-being of all children and fulfil their rights.

About the author

Louise Holly
Policy & Research Consultant, GHF2030 Secretariat
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