Children's Rights Should Guide Japan's Online Safety Policy

In June, a working group at Japan's Internal Affairs Ministry declined to endorse a blanket age-based social media ban for children, saying it was "not desirable." Although the group’s report is not yet final, its rejection of a blanket ban suggests a willingness to consider alternative approaches to protecting children online.
As Human Rights Watch said in our response, online safety measures should respect children's rights and, consistent with international human rights law, any restrictions on those rights should be lawful, necessary, and proportionate. A blanket ban fails that test.
The draft report proposes several safeguards, including requiring platform operators to conduct and publish risk assessments and protection measures, establishing an external mechanism to review those measures, and implementing default-on protections.
However, the report frames its recommendations as risk management measures rather than measures to protect children’s rights. A children’s rights approach starts by recognizing that children are entitled to a full range of rights guaranteed under the United Nations Convention on the Rights of the Child, which Japan ratified in 1994. The working group should ground its recommendations on the convention and Committee on the Rights of the Child’s General Comment No. 25 on the digital environment.
The government should also be more ambitious in addressing gaps in protecting children's data. Rather than relying solely on technical solutions that may be outdated as digital technologies evolve, policymakers should propose future-proof solutions.
Human Rights Watch research on educational technology products—including applications recommended by Japan’s Education Ministry —found that the vast majority of these products secretly surveilled children and sent their data to third parties for behavioral advertising.
The government should either amend the Act on the Protection of Personal Information to include comprehensive protections for children’s data or enact a new child data protection law with effective implementation, enforcement mechanisms, and adequate resources.
Such legislation should require companies to apply the most protective privacy and safety settings by default. Such settings should also include disabling recommendation algorithms, infinite scroll, and push notifications. Strong data protection safeguards could also help mitigate the privacy and human rights risk associated with collecting and processing children’s data for age verification purposes.
By placing children's rights and data protection at the center of this policy process, Japan has an opportunity to create a stronger model for protecting children online.

Facts Only

* A working group at Japan's Internal Affairs Ministry declined to endorse a blanket age-based social media ban for children in June.
* The draft report proposed requiring platform operators to conduct and publish risk assessments and protection measures.
* The draft report suggested establishing an external mechanism to review those measures.
* The draft report recommended implementing default-on protections.
* The recommendations were framed as risk management rather than direct measures to protect children’s rights.
* The recommendation is to ground policies in the United Nations Convention on the Rights of the Child and General Comment No. 25.
* Policymakers should enact a new child data protection law or amend the Act on the Protection of Personal Information for comprehensive protection.
* Legislation should require companies to apply the most protective privacy settings by default, including disabling recommendation algorithms and push notifications.
* Data protection safeguards could mitigate risks associated with collecting and processing children’s data for age verification.

Executive Summary

A working group at Japan's Internal Affairs Ministry declined to endorse a blanket age-based social media ban for children, deeming it undesirable. The group’s draft report proposed several safeguards, including requiring platform operators to conduct and publish risk assessments, establishing an external review mechanism, and implementing default-on protections. However, the recommendations were framed as risk management rather than direct protection of children's rights. The text suggests that policy should be grounded in the United Nations Convention on the Rights of the Child and the Committee on the Rights of the Child’s General Comment No. 25 on the digital environment. Furthermore, there is a call for governments to move beyond technical solutions by enacting comprehensive child data protection laws that mandate default privacy settings, disable tracking features like recommendation algorithms, and provide effective enforcement mechanisms for companies handling children's data.

Full Take

The dynamic presented involves a tension between technical risk management and fundamental human rights obligations regarding children's data. The shift from a policy focused on technological mitigation to one centered on recognizing inherent rights—as codified in the UNCRC—highlights a critical juncture in governance: whether regulation is framed as compliance with external standards (risk assessment) or as an acknowledgment of internal entitlements (rights protection). The failure of a blanket ban to meet the standard of lawfulness, necessity, and proportionality suggests that restrictive measures must be narrowly tailored. The move toward data legislation, mandating privacy-by-design through default settings, reflects a pattern where technological evolution outpaces legal frameworks, creating an opportunity for systemic exploitation. The juxtaposition of surveillance concerns found in educational technology research with the need for strict data governance implies that the potential beneficiary of these systems—children—is systematically positioned as the vulnerable party bearing the costs of inadequate regulatory structures. What prevents policy from being solely a reactive response to immediate threats, and how can recognizing rights intrinsically change the incentives for technological development?

Sentinel — Human

Confidence

The text reads like an analytical piece synthesizing external reports to build an argument for a specific policy direction, exhibiting the flow and critical synthesis typical of informed journalism or advocacy writing.

Signals Detected

Moderate sentence length variance; uses formal legal/policy phrasing interspersed with more direct argumentation.

Clear, structured argument flowing from a specific finding (the working group's rejection) to broader policy implications (rights vs. risk management).

Effective use of external citations (HRW, UN Convention) supporting claims; the structure mimics established advocacy reporting.

Claims rely on citing specific entities (Japan Ministry, HRW research) and legal frameworks, suggesting grounding in external sources rather than pure fabrication.

Human Indicators

Incorporates nuanced critique regarding the framing of policy recommendations (risk management vs. rights protection), which suggests interpretive human engagement.

Effective integration of multiple, disparate thematic threads (digital safety, data privacy, human rights law) into a single coherent argument.