Children's Privacy and Robots

What a child's robot can collect

A connected robot can gather far more than a toy box ever held: voice recordings, photos and video, a child's name and age, the times they play, their answers to games and, through the app, a location. The US Children's Online Privacy Protection Rule, 16 CFR Part 312, counts a photograph, video or audio file containing a child's image or voice as personal information, which shows how seriously regulators treat these recordings. Before you buy a robot such as the Miko 3, Cozmo or the Roybi Robot, read its privacy notice for what is recorded, where it is stored and who it is shared with. If any answer is vague, ask the maker in writing and keep the reply.

The UK children's code and connected toys

In the UK, the Information Commissioner's Office's Age appropriate design code sets 15 standards for online services likely to be used by children, and one of them covers connected toys and devices. Settings must be high privacy by default, geolocation and profiling should be off by default, and nudge techniques must not push children to share more or weaken their protections. If parents can monitor a child through the service, the child should get an obvious sign that this is happening. The ICO has also published a sample data protection impact assessment for a connected toy, drafted with a toy maker. Asking a seller whether its robot was designed against the code is a quick test of how it treats children's data.

US rules for children under 13

In the United States, the COPPA Rule defines a child as someone under 13 and requires an operator to obtain verifiable parental consent before collecting, using or disclosing a child's personal information. The current rule, last amended in April 2025, says information may be kept only as long as reasonably necessary for the purpose it was collected for, and operators must keep a written data retention policy. Even if you live elsewhere, those duties give you good questions for any maker that sells in the US. Ask how consent is checked, how long voice clips and images are kept, and whether you can see and delete them from the parent account.

Settings to check before a child plays

Spend half an hour in the app before handing the robot over. Turn off features you will not use, such as remote video viewing, photo sharing or location. Check whether the robot shows a light or plays a sound when its camera or microphone is active, and explain that signal to your child. Look for a setting that stops recordings being kept for product improvement, and find the option that deletes stored history. If the robot lets friends or relatives connect, limit who can join. Repeat the check after major app updates, since defaults can change. Finally, talk with your child about what the robot hears, in words that suit their age.

Sources and further reading

• Age appropriate design code: code standards — Information Commissioner's Office (ICO).
  The 15 standards of the UK children's code, including privacy by default and a standard for connected toys.
• Sample data protection impact assessment: connected toy — Information Commissioner's Office (ICO).
  Worked example, drafted with a toy maker, of assessing privacy risks in a connected toy under the children's code.
• 16 CFR Part 312: Children's Online Privacy Protection Rule — Federal Trade Commission (eCFR).
  US rule on collecting data from children under 13: parental consent, voice and image data, and retention limits.

Common questions

Is a second-hand children's robot a privacy risk?

It can be if the previous owner's account, recordings or Wi-Fi details were never removed. Ask the seller to delete their account and reset the robot before handing it over, then set it up fresh under your own parent account and check that no old profiles remain.

Should I cover the camera on my child's robot?

If you do not need the camera features, a cover or the off switch is a sensible step. Some robots use their cameras to move around or recognise faces, so check what stops working first, and make sure a small cover cannot be peeled off and swallowed by a young child.