Protecting Children's Personal Data in Iran: An Analysis of Legislative Gaps and a Strategic Roadmap Comparative View on EU and UK Regulations

Articles in Press

Document Type : Research Paper

Authors

1 Faculty of Management, University of Tehran

2 Department of Law, Non-Profit Welfare School, Tehran, Iran

Abstract

The rapid expansion of digital technologies has exposed children to unprecedented data-driven risks. The particular vulnerability of this age group to the collection, processing, and commercial exploitation of personal data amplifies the need for specialized protective frameworks. Despite legislative efforts, Iran's legal system primarily focuses on protecting children from harmful content and suffers from the absence of a cohesive, data-centric regime. Using a comparative-legal analysis, this research examines leading international models, particularly the European Union's General Data Protection Regulation (GDPR) and the UK's Age Appropriate Design Code. The findings indicate these models have adopted a preventive, design-based approach by introducing fundamental principles such as the “best interests of the child”, “privacy by design”, and practical mechanisms like “verifiable parental consent” and “Data Protection Impact Assessments”. In contrast, an analysis of Iran's draft “Personal Data Protection Bill” reveals deep structural weaknesses and an insufficient approach to children's rights, notably by reducing protection to the traditional concept of “legal incapacity”. Ultimately, by identifying existing gaps, this article presents a strategic legislative and executive roadmap. This roadmap is founded on the necessity of enacting a “Special Law for the Protection of Children's Data”, which would recognize the “best interests of the child” as the governing principle and mandate operational mechanisms such as “verifiable parental consent” and the requirement for a “child-focused Data Protection Impact Assessment”. Furthermore, while analyzing institutional challenges, the article proposes a model for establishing a specialized supervisory authority tailored to Iran's legal structure.

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Comparative Law Review

Articles in Press, Accepted Manuscript
Available Online from 11 December 2025

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