This policy sets out PPP and all of its subsidiaries and brands’, including OWL, the OWL mobile application, BOP, BLAK Magazine, AGA and BuildRSA’s, binding and unwavering commitment to the protection of minor children in all digital environments that we’re involved in. We at all material times strive to ensure full compliance with South African law, international treaties and the child-safety requirements of global app distribution platforms such as the Google Play and Apple App stores alike. In parallel with our mandate of safeguarding the information of adults, this policy’s purpose is specifically to endeavour to safeguard every person under the age of eighteen from any type of online exploitation, abuse and exposure to harmful content or contact, whilst protecting their rights to privacy, participation and safe access to online services. PPP has gone to great lengths to embed safety-by-design into all our products, including the OWL application and other services, which is supported by our efforts at active monitoring, reporting and enforcement.
As such, this policy has at its foundation the binding international instruments including the UN Convention on the Rights of the Child and its Optional Protocols, the Council of Europe’s Lanzarote Convention, and the Budapest Convention on Cybercrime, as well as other recognised global frameworks such as the OECD Recommendation on Children in the Digital Environment. It specifically incorporates South African obligations under the Children’s Act, the Films and Publications Act, the Cybercrimes Act and the Protection of Personal Information Act, as well as global data-protection legislation and regulations such as COPPA, the EU and UK GDPR.
We at PPP are committed to the prohibition of the unlawful collection or sharing of children’s personal information, restriction of tracking and commercial profiling, moderation of all user-generated content and enforcement of strict parental controls for interactive or transactional features. This also extends to the immediate removal and reporting of child sexual abuse material and grooming activity and swift cooperation with relevant authorities worldwide to uphold the highest standard of online safety.
Priority Performance Projects upholds the principles enshrined in the South African Constitution, the Children’s Act 38 of 2005, as well as all international treaties and conventions, ensuring that every child’s best interests are of paramount importance in every matter concerning them. We are dedicated to promoting the physical, emotional and psychological safety of all children, and to preventing any form of abuse and exploitation. We follow a proactive approach by embedding preventive safeguards in our systems and maintain a zero-tolerance approach toward the violations of children’s rights. Should any child protection concern arise, PPP will act with the necessary decisive action and in full cooperation with relevant authorities across any jurisdictions to ensure that these risks are neutralized.
PPP’s digital platforms, which includes our website and mobile applications such as OWL, are specifically designed in accordance with the child-safety, privacy and data-handling requirements of both the Google Play Families Policy and the Apple App Store Review Guidelines for the Kids Category. As such we do not knowingly collect, use or disclose any personal or special personal information from children under the applicable legal age of digital consent in their jurisdiction without obtaining verifiable parental or legal guardian authorisation. We strive to ensure that where applicable, all child-directed content is suitable and appropriate for the intended age group, free from prohibited material and subject to robust moderation to prevent exposure to harmful or unsafe interactions from malicious players. Our design, content, and operational practices adhere to both legal obligations and recognised international best-practice standards for online child protection.
All staff, volunteers, partners and users of the PPP platform are required to report suspected abuse, exploitation, misconduct or any other safety concerns involving children with immediate effect. These reports may be made directly to and will be acted upon swiftly in accordance with South African law, applicable international obligations and the requirements of the Google Play Families Policy and Apple App Store Guidelines. In addition to our own organisational vigilance, all parents and legal guardians of minor children share a critical responsibility to actively monitor their children’s online activities, to utilise the available parental control features of devices and software alike, and to immediately report any suspicious behaviour, inappropriate content and or safety concerns encountered on our platforms. This shared responsibility between PPP and caregivers is utterly critical to maintaining a secure, lawful and protective digital environment for all child users.
PPP will at all material times endeavour to ensure compliance with all relevant South African child protection laws and aligns its practices with the Protection of Personal Information Act (POPIA) to ensure that children’s personal information is collected, processed and stored with the highest level of confidentiality and accountability possible. As indicated, our compliance framework also aims to incorporate various other international treaties, conventions and mobile application platform-specific requirements to uphold global standards of online child safety.
In particular, PPP’s policies and operations aim to adhere to: a) Constitution of the Republic of South Africa, Children’s Act 38 of 2005, Films and Publications Act (as amended), Cybercrimes Act 19 of 2020, Protection of Personal Information Act 4 of 2013 (POPIA) b) United Nations Convention on the Rights of the Child, Optional Protocols to the United Nations Convention on the Rights of the Child, Council of Europe Convention on the Protection of Children against Sexual Exploitation and Sexual Abuse (Lanzarote Convention), Convention on Cybercrime (Budapest Convention), OECD Recommendation on Children in the Digital Environment c) Children’s Online Privacy Protection Act (COPPA), European Union General Data Protection Regulation (GDPR) Article 8, United Kingdom General Data Protection Regulation (UK GDPR), Age-Appropriate Design Code d) Google Play Families Policy, Apple App Store Review Guidelines for the Kids Category