The debate over the regulation of digital platforms to protect children from illegal or harmful content has gained momentum following the recent proposal to use Clave Única (Chilean digital ID system) as an identification mechanism.
As civil society organizations with expertise in human rights and technology, we recognize the urgency of protecting children and adolescents from real risks online, such as harassment, sexual exploitation, grooming, exposure to harmful content, algorithmic manipulation, the abusive use of personal data, and platform designs oriented toward capturing their attention. However, we warn that any public policy in this area must be effective, proportionate, evidence-based, and respectful of everyone’s rights, which also means not exposing children and adolescents, nor the public at large, to greater risks to the security of their information. The possibility of using Clave Única as a mechanism to verify the age of children and adolescents accessing social media and digital platforms is a troubling proposal, particularly because of its impacts on privacy, personal data protection, security, and the exercise of rights in the digital environment.
Clave Única does not only allow a person’s identity to be certified; it also enables the processing of personal data by defining how it is used, for how long, under what control, and to whom one can turn if something goes wrong. In this case, using the digital identity system to access social media entails creating a centralized and traceable record of each user’s internet activity, which carries a heightened risk of surveillance, security breaches, and misuse of personal data. In practice, any age verification system should strictly comply with the principles of data minimization, security, proportionality, transparency, and independent oversight, while also achieving a balance that safeguards other fundamental guarantees that should not be disproportionately restricted, such as freedom of expression.
Furthermore, we cannot help but be concerned that mandatory identification as a condition of access could particularly affect adolescents who use the internet to seek information about mental health, sexuality, violence, identity, orientation, community support, or reporting mechanisms for situations they experience offline. For many children and adolescents, particularly those living in more vulnerable circumstances, digital spaces are a key source of information, belonging, expression, and support.
While we value the Government’s acknowledgment that conversations on this matter remain pending and that the goal would be to move toward age verification systems rather than identity verification systems, we call for proactive action that goes beyond simply acknowledging that conversations remain pending—action that also opens spaces for civic participation to build broad, informed, and transparent consensus on the risks, limits, safeguards, and alternatives to any measure in this area.
We also believe it is important to bear in mind that General Comment No. 25 of the UN Committee on the Rights of the Child establishes that children’s rights must also be guaranteed in the digital environment. This includes their right to access information, express themselves, participate, develop their identity, receive protection from harm, and enjoy privacy appropriate to their age and evolving autonomy.
Likewise, we point out that focusing the response solely on age verification may displace the underlying problem: that digital platforms are not safe by design. We have seen this recently in cases of the non-consensual dissemination of intimate content through messaging app groups, the creation of deepfakes, and other related harms.
For this reason, we maintain that the discussion should not be reduced to who may access a platform, but rather to who must be held accountable for ensuring that these environments are safe by design. Platforms must have clear and enforceable obligations, such as limiting the collection and use of children’s and adolescents’ data; prohibiting abusive commercial practices; making their recommendation systems transparent; offering privacy-protective settings by default; providing accessible complaint and reporting mechanisms; and responding promptly when harms occur, especially those of an intimate nature.
Alongside this, it is necessary to bring the debate to bear on digital education and literacy at the national level as well. While Chile is a highly internet-connected country, significant gaps remain in how it is used, which are reflected in the rise of fraud, digital scams, extortion, and account takeover, among other areas that, absent a national educational program on these issues, will continue to grow.
Finally, we express our willingness to engage in dialogue with the Government, Congress, academia, educational communities, civil society, and children and adolescents themselves, to build a public policy that protects them effectively, without sacrificing privacy, security, access to information, and freedom of expression.
Signatory Organizations
Asociación Chilena Pro Naciones Unidas – ACHNU
Asociación de Abogadas Feministas de Chile
Colegio de Periodistas de Chile
Confianza Digital
Corporación Humanas
Corporación La Caleta
Corporación Miles
Derechos Digitales
Digital Action
Fundación Kamanau
Fundación LIBERTECH
La chispa digital
Observatorio del Derecho a la Comunicación (ODC)
ONG Amaranta
Wikimedia Chile