Canada’s new Children’s Privacy Code addresses emotional analytics

The Office of the Privacy Commissioner of Canada (OPC) has published its Children’s Privacy Code. The code includes a section on emotional analytics, listed under prohibited practices. It says organisations must not use children’s personal information to infer emotional states or vulnerabilities in order to exploit them.

This is an issue we examined in The Machine-Readable Child: Governance of Emotional AI Used with Canadian Children. Andrew McStay and Gilad Rosner (Internet of Things Privacy Forum) wrote that report for the OPC’s Contributions Program in 2025. It found that Canadian privacy law lacked specific protections for children’s emotion data and recommended changes to address this.

We welcome the OPC’s recognition of emotional analytics as a distinct risk to children.