Subject: Estonia Digital Child Protection Laws
From: "Tom Nash" <[email-masked]>
To: "AKI info"
Date: Wed, 26 Feb 2025 02:29:43 +0200

Tähelepanu! Tegemist on välisvõrgust saabunud kirjaga.
Tundmatu saatja korral palume linke ja faile mitte avada.

Dear Estonian Data Protection Inspectorate:
I am the Chief Operating Officer for a software company in the USA called
Warning Technologies, Inc. Warning Technologies is developing an online
cloud-based warning and messaging platform for educational institutions
and students. Confidential warnings could be about bullying, adult abuse,
drug or alcohol abuse, depression, threats of violence, threats of
suicide, etc.

The system is designed to automatically route confidential warning
messages from the community around a school (students, parents, etc.) to
the person designated by the educational institution to assess and
coordinate any necessary response to each type of warning. The warnings
can be sent via the portal on our website or by using our smart phone app.
The system is school- or school district-specific and highly configurable.
In some areas we will be able to offer the option of connecting real-time
to first responders such as the Police, Fire Department, and Emergency
Medical Services.

Our platform is secure, highly configurable, and we are designing it to
support all applicable privacy rules and laws in various countries. The
system also includes provisions to minimize or eliminate false alarms and
the use of the system itself as a bullying tool, something that has been a
serious problem with other less-sophisticated “tips” systems. For that
reason we do not allow anonymous warnings. Our system allows authorized
administrators to backtrack to a specific sender in cases of abuse of the
system or attempts to use it as a bullying tool.

As the amount of data for a school, a school district, or a geographic
region grows, predictive AI will help identify trends, allowing informed
proactive and preventative responses by the school or district rather than
reactive responses driven by real-time crisis.

Registering to use our system will require the user’s name, e-mail
address, and a mobile telephone number. The European Union General Data
Protections Regulations (GDPR) requires that any information collected
from a child under the age of 16 must be with verified parental consent.
However, the GDPR also states that individual EU members may choose a
different age of consent. Therefore, I am writing to you to understand
several aspects of these requirements within your country:

1.	What is the age of consent in your country for a software system
to collect a child’s name, e-mail and telephone without parental consent?

2.	What is considered to be Verified Parental Consent in your
country?  What form does that take? We are well aware that some countries
have gone nearly completely digital, but please keep in mind that as an
American software company we do not typically have access to any national
online systems that your country uses. If this is a requirement, please
tell me how we can make an application to interface with and participate
in that system. Conversely, can we verify parental consent by storing a
digital copy of the parent’s driver’s license, passport, or some other
typical document a parent in your country might possess?

3.	Do you have a web site, pdf document, or other means of describing
the child privacy laws in your country that we can use as a guide to
assure that our system meets or exceeds your privacy standards?

Thank you for your time and consideration.

Respectfully yours,

---------------------------------------------
Tom Nash
Chief Operating Officer
Warning Technologies, LLC
[email-masked]
+1 (415) 767-8824 mobile
https://warningtechnologies.com/