Practice profile
Credentials
Not a table of statutory contrasts. The seven places where the two regimes diverge enough to change your data model, your consent screens and your engineering backlog.
The designation is discretionary, so the useful question is not whether you are one but what it would cost to be treated as one. Three additional duties, and why we tell large consumer platforms to assume it.
The Act set the principles. The Rules set the engineering requirements. Here is what changes in your systems — notice structure, breach clocks, and verifiable parental consent.
Deleting the row is the easy part. The obligation reaches analytics copies, backups, processor-held data and — the unresolved question — models trained on data that has since been withdrawn.
A consent banner records a choice. A consent architecture enforces it. Here is the two-hour test that shows which one you have — and how to fix the gap.
Independence is not a job title. It is a reporting line, a documented advice trail, and protection from consequence. Here is what regulators look for and what fails.
