The DPC said it had received a number of complaints concerning the processing of children’s personal data on Instagram and had identified potential concerns which require further examination.

The first inquiry will assess Facebook’s reliance on certain legal bases for its processing of children’s personal data on the Instagram platform.

The DPC will set out to establish whether Facebook has a legal basis for the ongoing processing of children’s personal data and if it employs adequate protections and/or restrictions on the Instagram platform for such children.

This inquiry will also consider whether Facebook meets its obligations as a data controller with regard to transparency requirements in its provision of Instagram to children.

The second inquiry will focus on Instagram profile and account settings and the appropriateness of these settings for children.

Amongst other matters, this inquiry will explore Facebook’s adherence with the requirements in the GDPR in respect to Data Protection by Design and Default and specifically in relation to Facebook’s responsibility to protect the data protection rights of children as vulnerable persons.