For example, a parent or guardian could be asked to make a payment of€0,01 to the controller via a banktransaction, including a brief confirmation in the description line of the transaction that the bank account holderis a holder of parental responsibility over the user. Where appropriate, an alternative method of verificationshould be provided to prevent undue discriminatory treatment of persons that do nothave a bank account.

The EDPBacknowledges that there may be cases where verification is challenging (for example wherechildren providing their own consent have not yet established an ‘identity footprint’, or where parentalresponsibility is not easily checked.

If the user states that he/she is below the age of digital consent then the controller can accept thisstatement without further checks, but will need to go on to obtain parental authorisation and verifythat the person providingthat consent is a holder of parental responsibility.