This short submission addresses a specific proposal in the Industry Standards for Class 1A & 1B Material for Designated Internet Services and Relevant Electronic Services. It highlights concerns that the minimum age of default privacy settings violates children’s rights and these decisions do not appear to be made in children’s best interests. 

In particular, the proposals:

• violate children’s right to protection and to privacy through privacy-by-default settings
• violate children’s rights by capping protections at 16
• raise procedural concerns.