The encyclopedia · Legal & Compliance · Legal decision · 2020–2023
TikTok made children's accounts public by default — the Irish DPC fined it €345M
Child accounts started public, family controls had holes, age checks were skipped — the DPC's €345M fine covered just five months of this.
TikTok · 2023-09-15
What happened
On 15 September 2023 Ireland's Data Protection Commission announced a €345 million fine against TikTok over how it treated child users. The inquiry examined only five months — 31 July to 31 December 2020 — and found that accounts for users aged 13 to 17 were set to public by default on registration, visible to anyone.
The findings ran to eight GDPR violations: holes in the 'Family Pairing' controls meant to link a child's account to a parent, insufficient age verification at sign-up, and too little information given to children about the default settings. After a binding decision by the European Data Protection Board in August 2023, the DPC also found TikTok had used 'dark patterns' — design nudges that push users toward less private choices.
TikTok was reprimanded, ordered to bring its processing into compliance within three months, and fined the largest penalty it has received from any regulator. It said it respectfully disagreed, particularly with the level of the fine, and noted the criticised settings had been changed before the inquiry began — under-16 accounts became private by default in January 2021. The UK's ICO had already fined TikTok £12.7 million in April 2023 over under-13s on the platform.
Why it happened
- Defaults are the real privacy policy: most users never open settings, so whatever ships at registration is what governs.
- A five-month window produced a nine-figure fine, which is what happens when the daily gravity of the infringement is high — the scale of exposure, not the duration, drove the number.
- Fixing a setting after launch does not erase the period it ran; regulators fine the window, and 'we changed it later' is mitigation at best.
The lesson
Ship private-by-default for users who cannot protect themselves — the default you choose at registration is the one a regulator will measure, and fixing it later does not close the billing window.
Sources
- DPC announces €345 million fine of TikTok — Data Protection Commission
- TikTok fined €345m over children's data privacy — BBC News
spotted an error? The club wants to know.
More like this
Amazon's €746M GDPR record fine was scrapped on a technicality
AliExpress got a €550M EU fine — the DSA's first big test landed on Alibaba
Italy fines Replika's maker €5 million over GDPR and children's data
Somewhere, someone solved the problem this company failed at. 2nd Opinion →

Comments · 0
Sign in to join the comments.