Ghana’s digital transformation is no longer abstract. From mobile money transactions to the rollout of the Ghana Card, personal data now underpins how citizens access services, how businesses operate, and how institutions earn trust.
As we digitise adults’ lives, we are also digitising the lives of our children. Every school app, every educational tablet and every photo shared online contributes to a child’s growing digital footprint, often long before they understand what that really means.
In this evolving environment, data protection for children is no longer just a compliance requirement. It is central to building digital trust, enabling safe participation in the economy, and maintaining institutional credibility. For parents, schools, and businesses alike, understanding how to handle children’s data is now essential.
What is children’s data, and why does it matter?
A child is defined as anyone under the age of 18 years. Children’s data includes any information that can identify them, such as their name, date of birth, school records, location data, health information, biometric identifiers, photographs and videos.
Under the Data Protection Act 2012 (Act 843), children are treated as a vulnerable group, which means their data requires a higher level of care. In many situations, especially where sensitive details like health or biometric data are involved, this may qualify as “special personal data“, which brings strict legal safeguards into play.
Unlike adults, children are also less able to understand how their data might be used over time. This makes careful handling a legal, practical and ethical responsibility.
What the law requires: Consent is only the starting point
Under Act 843, one principle stands above all: a child’s personal data cannot be processed without the consent of a parent or legal guardian. But consent is only the starting point.
The law sets out clear expectations for any organisation handling this kind of information.
- Lawful basis: schools, clubs, healthcare providers, and apps or digital platforms must obtain clear, informed permission from a parent or guardian before collecting or using a child’s information.
- Purpose limitation: data can only be collected for a specific, stated reason. A school may need a birth date for class placement, but it cannot later share that data with a third party without fresh consent.
- Data minimisation: only what is necessary can be collected. If you do not need a child’s medical history to enrol in a football camp, do not ask for it.
- Security and retention: children’s data must be protected from breaches and deleted when it is no longer needed for its original purpose.
When these standards are not met, whether through a data leak, unauthorised sharing, or poor security, there are serious legal and reputational consequences for any organisation involved.
What this means for parents: The risks of “sharenting”
As a parent or guardian, you act as the gatekeeper of your child’s digital identity. But many parents now share their children’s images, videos, and milestones across social media; a practice sometimes called “sharenting.”
Under Ghanaian law, this carries real risks. Legal experts have warned that posting humiliating, overly commercial, or excessively detailed content about a child could breach that child’s right to privacy. There are documented cases where the Department of Social Welfare has intervened in such matters.
If a brand or influencer wants to use your child’s image, more than verbal consent is required. Legal permits from the Labour Department and the Ghana Standards Authority may be necessary to protect the child financially. Ghanaian children also have the right to privacy and dignity, and in a recent survey, students themselves said they wanted more control over their personal information online.
What does this mean for your organisation?
Whether you run a school, a hospital, a fintech app, or an entertainment platform, handling children’s data goes beyond a consent form. It requires ongoing accountability and thoughtful systems.
Key responsibilities include;
Appointing a Data Protection Officer (DPO): organisations handling sensitive or large volumes of children’s data must designate a DPO to oversee compliance and act as a bridge between the organisation, regulators, and parents.
Conduct Data Protection Impact Assessments (DPIAs): before launching any activity that poses a high risk to children, such as using biometric attendance systems or AI-driven learning tools, you must assess and mitigate potential risks.
AI safeguards: systems that process children’s data should include strong protections to prevent profiling, misuse, or the generation of harmful or non-consensual content involving minors.
Who enforces the rules?
The Data Protection Commission (DPC) is Ghana’s independent regulator. The DPC has the power to issue enforcement notices, impose fines, and prosecute offenders. It also runs nationwide awareness campaigns to educate students and the public about their data rights.
In short, children’s data is not a grey area. It is a regulated space with clear rules, active enforcement, and serious consequences for non-compliance.
Protecting Ghana’s digital future, starting with its children
Data protection in Ghana is central to supporting economic participation and sustainable growth. But a truly trusted digital economy must protect every citizen, especially the most vulnerable.
For parents, that means thinking before sharing. For schools, healthcare providers, and technology platforms, it means treating children’s privacy as a core responsibility, not an administrative afterthought.
If your organisation processes children’s personal data within Ghana’s evolving digital ecosystem, having expert guidance is now essential. HewardMills can help by providing the specialist Data Protection Officer support you need to strengthen governance frameworks, build trust with parents, and mitigate legal risk.
Contact our experienced team in Ghana to discuss how we can support your data protection and compliance objectives.
