Legitimate Interests Assessment (LIA)

Version: Nov 2026

Video- and audio recording of padel matches and technical error diagnostics via Padel Platform

Company

Padel Platform ApS

Legal basis for processing

GDPR Article 6(1)(f)

Version

4.1

Date

November 6th 2026

Document type

Internal documentation of the balancing of interests

1. Purpose and scope

The purpose of this LIA is to document Padel Platform ApS' assessment of whether the processing of ordinary personal data in connection with video and audio recording of padel matches may be based on legitimate interests under Article 6(1)(f) of the GDPR.

The assessment covers video and audio recording, storage, replay, automatically generated highlights, linking with match data and statistics, sharing and livestreaming. The assessment does not cover HealthKit data or other special categories of personal data.

The LIA follows the three-part test under Article 6(1)(f): (1) legitimate interest, (2) necessity and (3) balancing against the interests, rights and freedoms of the data subjects.

This LIA also includes a separate balancing of interests for technical error diagnostics and stable operation, see section 13.

2. Actual technical and functional processing

  • A player creates the match in Padel Platform.

  • Video and audio recording is disabled unless the match organiser actively selects the recording option before the match starts. Once selected, recording starts when that match is started using the supported scoring or match-start method (for example Apple Watch or Point PODS); starting a match without selecting recording does not activate the camera or microphone.

  • The recording stops when the player selects "End Match".

  • The camera is fixed, directed at one specific court and cannot pan or zoom.

  • The camera's field of view is limited to the court itself and does not show areas outside the court.

  • The microphone is integrated into the camera, directed at the court and records at the same time as the video. The user cannot select video without audio.

  • It is not technically possible to prevent the microphone from also capturing sounds or conversations outside the court.

  • Recordings are stored in Microsoft Azure in Sweden.

  • Access to a match recording is, by default, limited to the four players who participated in the match.

  • Sharing with a third party requires an active action by a player.

  • Only the player who created the match can personally delete the entire match recording through their account. Other data subjects may request erasure in accordance with the procedure set out in the Privacy Policy.

  • Match recordings are automatically deleted no later than 2 years after the recording, unless deleted earlier.

  • Highlights are generated automatically as separate files. They may be retained independently of the full match recording, but are also subject to a maximum retention period of 2 years.

  • Only the player who created the match may activate livestreaming before the match, and only where the pre-match control confirms that no player is under 15 years of age. Livestreaming is strictly prohibited if one or more participating players are under 15, including where parental approval has been provided. A negative or unknown age declaration must prevent activation. Viewing is through a shared HTTPS link; a livestream cannot be enabled retroactively through the match-claim flow.

  • Padel centre staff do not have access to the recordings.

  • Padel Platform administrators may obtain access where there is a specific legitimate need, for example support, troubleshooting, security or handling data subject rights.

  • For requests from persons without direct access, the recording is identified using information such as the centre, court, date and time.

  • There is currently no separate technical REC indicator on the court showing that recording is active. Transparency is instead ensured through clear signage at the court stating that video and audio are recorded, what activates the recording, that the microphone may capture sound from persons nearby, and when the recording stops.

3. Data subjects and personal data

3.1 Data subjects

  • The four players on the court.

  • Persons whose voice or other sound is unintentionally captured from areas outside the court.

As the camera's field of view covers only the court, the risk of visually recording passers-by outside the court is significantly limited. An equivalent complete technical limitation cannot be guaranteed for audio.

3.2 Data

  • Images and movements from the match.

  • Voice, speech and other sounds during the match.

  • Match identity, time and association with players.

  • Video/audio sequences and automatically generated highlights.

  • Match data and statistics when linked to the recording.

Under the solution described, no facial recognition, voice recognition or biometric identification is carried out.

4. Test 1 - legitimate interest

Padel Platform's interest is to provide a digital sports platform where players can relive, analyse and share their matches and use video and audio together with score, statistics and highlights.

  • Replay of matches.

  • Automatic generation of highlights and moments.

  • Match analysis and linking with statistics.

  • Ability to share actively.

  • Livestreaming where the player actively chooses this.

The interest is specific, current and directly linked to Padel Platform's product functions. The recording is not carried out for the purpose of general surveillance of the padel centre.

Conclusion: Test 1 is considered satisfied.

5. Test 2 - necessity

5.1 Video

Video is necessary for replay, video highlights and visual match analysis. These functions cannot be provided in an equivalent manner without recording the match itself.

5.2 Audio

Audio forms an integral part of the audiovisual reproduction of the match, including replay, highlights and livestreaming. The functions can technically exist without audio, but would then not provide the intended audiovisual sports experience.

The necessity assessment for audio is therefore less clear-cut than for video. Weight is given to the fact that the microphone is directed at the court, that audio is recorded only during an active match recording, and that recording does not take place continuously.

However, it cannot technically be ruled out that conversations or sounds outside the court are captured. This is addressed as a separate risk in the balancing test.

5.3 Less intrusive alternatives

Padel Platform has considered the following alternatives:

  • Continuous recording is not necessary and is therefore not used.

  • A camera recording surrounding areas is not necessary; the camera is therefore fixed and limited to the court.

  • Public access by default is not necessary; recordings are therefore limited to the four players in the match.

  • Automatic public sharing is not necessary; sharing requires an active action.

  • Unlimited retention is not necessary; automatic deletion takes place no later than after 2 years, with the possibility of earlier deletion.

For audio, an alternative is video without audio. Padel Platform has assessed that this would not fulfil the defined purpose of an integrated audiovisual reproduction as effectively. The greater privacy impact of audio must therefore be mitigated through clear information, technical direction towards the court, access restrictions, user-initiated sharing and deletion.

Conclusion: Test 2 is considered satisfied for the processing described, but audio requires heightened attention and the safeguards described.

6. Test 3 - balancing of interests

6.1 Reasonable expectations and transparency

Recording takes place only on a court equipped with a Padel Platform camera, where signage states that video and audio may be recorded. The match organiser must actively select recording before the match begins and inform the other players. Only after this selection does recording begin when the particular match starts; recording ends at "End Match". Starting a match alone does not activate recording.

This reduces the risk that players and persons nearby perceive the processing as hidden or unrelated. There is no separate active REC indicator. The absence of such an indicator is addressed through clear signage describing when recording is activated and when it ends. An active recording indicator may be considered as an additional transparency measure if this later becomes technically possible, but it is not relied upon as an existing control in this LIA.

6.2 Limitation of video

The camera is fixed, cannot pan or zoom and shows only the specific court. This is an important privacy-by-design measure because the visual processing is limited to the persons present on the court.

6.3 Specific assessment of audio

Audio is more intrusive than images alone because the recording may contain speech and conversations. The microphone is directed at the court, but it cannot technically be prevented from capturing sounds or conversations outside the court.

This risk is reduced because the microphone is active only at the same time as a specific match recording, there is no continuous recording, access is restricted by default, and clear signage is provided regarding both video and audio.

The risk cannot be eliminated completely. The audio function should therefore be kept under review, and the direction/sensitivity of the microphone should be limited as far as possible without undermining the intended function.

6.4 Access and sharing

Recordings are, by default, limited to the four players in the match. A recording does not become publicly available merely by being recorded. Sharing with a third party requires an active action by a player.

Livestreaming is available only for a match that was configured before play by the match creator and for which the active age declaration states that no player is under 15. It is disabled whenever a participant is under 15, or age is unknown or not confirmed. Parental approval is not an exception. Viewers use an actively shared HTTPS link and onward distribution cannot be fully controlled. Padel centre staff do not have access to recordings.

Padel Platform administrators have technical access, but access must be limited to specific legitimate needs such as support, troubleshooting, security and handling data subject rights.

6.5 Retention - up to 2 years

Match recordings and highlights may be retained for up to 2 years. The period supports the product purpose of enabling players to build a history, revisit previous matches, follow their development over time and use recordings together with statistics and highlights.

Two years is a maximum period and does not require every recording to exist for the full period. The player who created the match may delete the recording earlier. Other data subjects may request erasure.

Automatic deletion at the end of the maximum period reduces the risk of indefinite retention. "Highlights" and "moments" are separate files but are subject to the same maximum period.

6.6 Data subject control and rights

The player who created the match can personally delete the recording through their account. Co-players and other persons who believe they appear in a recording may contact the player who initiated the recording or Padel Platform. Padel Platform can identify relevant recordings using, among other things, the centre, court, date and time.

Data subjects may object to processing based on legitimate interests. Any such objection must be assessed individually in accordance with the GDPR.

6.7 Children and young people – age-dependent distinction

Children merit particular protection. Ordinary, non-public match video/audio recording involving players under 15 may be considered under Article 6(1)(f), subject to the documented, child-specific balancing assessment and safeguards in Appendix C; parental approval is not automatically required by Article 8 where the processing relies on Article 6(1)(f). This is not blanket permission: the purpose, audio, notice, age-related risks, access restrictions, sharing and retention must be evaluated. Livestreaming of a match involving any player under 15 is prohibited without exception. For all pre-match recording and streaming choices, the organiser is asked whether anyone under 15 will play; if yes or unknown, streaming must be disabled. A declaration alone is not a guarantee of accurate ages. Data subjects’ objections and erasure requests need particular care, especially for children.

Conclusion: Subject to the limitations and controls described, Padel Platform considers that its legitimate interests are not, as a general rule, overridden by the interests, rights and freedoms of the data subjects. Audio does, however, involve a higher residual risk than video.

7. Risk assessment and controls

Risk

Inherent risk

Control/mitigation

Residual risk

Visual recording of players

Medium

Fixed camera; court only; match-based activation; private access by default

Low

Unintentional audio/conversations outside the court

High

Microphone directed at the court; active only during match; signage; restricted access

Medium

Lack of clarity as to active recording

Medium

Clear signage states video + audio, what starts the recording, possibility of audio from persons nearby and when recording stops.

Low/medium

Unauthorised access

High

Access limited to four players; administrator access only where there is a legitimate need; centre has no access

Low/medium

Unwanted sharing

Medium/high

Sharing requires active action; livestream requires active start and active sharing of HTTPS link

Low/medium

Excessive retention

Medium

Maximum 2 years; automatic deletion; possibility of earlier deletion

Low/medium

Erasure request from co-player/third party

Medium

Procedure via initiator or privacy contact; identification via centre/court/date/time

Low

Highlights remain after deletion of full match

Medium

Highlights are separate files and must be handled separately where a relevant erasure request covers them; maximum 2 years

Low/medium

8. Technical and organisational measures

  • The camera is fixed and limited to one court; no pan/tilt/zoom.

  • Recording takes place only during an actively started match and stops at "End Match".

  • The microphone is directed at the court.

  • Clear signage is provided regarding video and audio recording, including what starts the recording, that the microphone may capture sounds and conversations from persons nearby, and when the recording stops.

  • Access to the recording is, by default, limited to the four players in the match.

  • Sharing requires an active user action.

  • Livestreaming requires an active pre-match request, an age declaration indicating no participants under 15, an enforced block where a child is present or age status is unknown, and active sharing of an HTTPS link; retrospective activation after claim is not permitted.

  • Padel centre staff do not have access.

  • Administrator access is used only where there is a specific legitimate need.

  • Recordings and highlights are automatically deleted no later than after 2 years.

  • The player who created the match may personally delete the recording earlier.

  • A procedure exists for requests from co-players and other data subjects.

9. Recommended improvements

The following improvements are not described as existing functions, but are recommended in order to reduce residual risk:

  • Consider a clear active recording indicator on the scoreboard, camera or similar as an additional transparency measure if this later becomes technically possible. The current solution relies on clear signage at the court for transparency.

  • Document and test the microphone's actual recording range and adjust its direction/sensitivity if unrelated conversations outside the court are captured more than necessary.

  • Ensure that administrator access is role-based and, where technically possible, logged so that access to match recordings can be audited.

  • Ensure that the erasure flow also identifies and handles separate highlight files where a specific erasure request covers them.

10. Overall conclusion

Padel Platform ApS has a specific and legitimate interest in providing private video, audio, replay, highlight and analysis functionality, and livestreaming for adult-only matches under the safeguards documented herein. Streaming is not available if a player is under 15.

The video recording is closely technically limited to the specific court and is necessary for the visual functions. Audio recording has a greater privacy impact, and the necessity assessment is less clear-cut, but audio is defined as an integral part of the audiovisual sports experience. The risk is reduced through match-based activation, a microphone directed at the court, signage, private access by default, active sharing, restricted administrator access, the possibility of deletion and automatic deletion no later than after 2 years.

On the basis of the solution described and provided that the stated controls are maintained, Padel Platform ApS considers that Article 6(1)(f) of the GDPR may be relied upon as the legal basis for the processing of ordinary personal data described.

This conclusion concerns Article 6(1)(f) of the GDPR. Audio recording under section 263 of the Danish Criminal Code is assessed separately in Appendix B. Appendix B does not alter the nature of this LIA as documentation of the GDPR legal basis for processing.

11. Relationship with other legislation

This LIA primarily concerns Article 6(1)(f) of the GDPR. It does not in itself constitute a legal basis under other Danish legislation. Padel Platform has therefore carried out a separate assessment of audio recording under section 263 of the Danish Criminal Code in Appendix B. Other relevant legal frameworks must continue to be assessed separately where applicable.

12. Review

The LIA must be reviewed in the event of material changes, including:

  • changes to the camera's field of view or functionality

  • changes to the microphone's recording range or audio processing

  • introduction of continuous recording

  • changes to the access or sharing model

  • changes to the retention period

  • new purposes for the recordings

  • AI-based analysis of images or audio

  • facial, voice or other biometric recognition

  • material complaints, incidents or changes in legislation/regulatory practice

The LIA should also be reviewed periodically, even where the product has not changed.

13. Technical error diagnostics and stable operation

Padel Platform ApS uses Sentry (Functional Software, Inc.) for technical error diagnostics of the website and iPhone app in order to identify and remedy errors, crashes and problems with the stability of the Service.

Legal basis for processing: GDPR Article 6(1)(f) (legitimate interests).

13.1 Legitimate interest and necessity

Padel Platform has a legitimate interest in ensuring stable, secure and well-functioning operation of the Service.

Automated error diagnostics are necessary to effectively identify and remedy technical errors, including errors that cannot readily be reproduced in development and test environments.

The processing is limited to technical information such as error messages, error codes, stack traces, information about device, browser, operating system, software version and time, and relevant technical events immediately preceding an error.

13.2 Data minimisation and safeguards

Padel Platform has implemented the following limitations:

  • Names, email addresses, telephone numbers, user IDs, passwords and access tokens are filtered out as far as possible before information is sent to Sentry.

  • IP addresses may be processed technically during transmission, but Sentry is configured not to store them in error reports.

  • Screenshots and user session recordings are not collected.

  • Error reports are used solely for technical operation and troubleshooting, not for marketing or user profiling.

  • Access to diagnostic information is limited to relevant employees.

  • The data is stored in Sentry's EU region.

  • The retention period is a maximum of 30 days after the end of the current trial period, during which the period may be up to 90 days.

It cannot be completely ruled out that personal data may inadvertently be included in technical error reports. Such data is handled and deleted in accordance with relevant procedures.

13.3 Balancing of interests and conclusion

Padel Platform considers that the legitimate interests in secure and stable operation generally outweigh the limited impact on data subjects' rights, provided that the described safeguards are implemented and maintained.

The processing is limited to technical error diagnostics, and data minimisation, access control and a short retention period are applied. Any personal data collected inadvertently must be handled and deleted in accordance with relevant procedures.

On this basis, the processing is considered capable of being carried out on the basis of GDPR Article 6(1)(f), subject to ongoing control of data minimisation, access restriction and the retention period.

Appendix A - Legal sources used as framework

The LIA is structured in accordance with Article 6(1)(f) of the GDPR and the standard three-part legitimate interests test: legitimate interest, necessity and balancing of interests. Particular regard has been had to the EDPB guidelines on legitimate interests and video processing.

  • Regulation (EU) 2016/679 of the European Parliament and of the Council (GDPR), Articles 5, 6, 13/14 and 21 and Recital 47.

  • European Data Protection Board, Guidelines 1/2024 on processing of personal data based on Article 6(1)(f) GDPR (version published for consultation in 2024).

  • European Data Protection Board, Guidelines 3/2019 on processing of personal data through video devices, final version 30 January 2020.

Note: This Appendix sets out the legal framework. The specific technical description in the LIA is based on information about Padel Platform's actual solution.

Appendix B - Separate assessment of audio recording under section 263 of the Danish Criminal Code

B.1 Purpose and scope

This Appendix documents Padel Platform ApS' separate assessment of audio recording in relation to section 263 of the Danish Criminal Code. The assessment supplements, but does not replace, the GDPR assessment in the LIA itself.

The assessment is based on the actual solution: the match organiser must actively choose video and audio recording before the match starts. When the selected recording is activated by the start of that match using a supported method, the camera and microphone on that specific court begin recording; no recording occurs merely because a match starts. Recording stops at "End Match". The camera is fixed and limited to the court. The integrated microphone is directed at the court but may technically capture sounds and conversations from persons nearby.

B.2 Legal starting point

Section 263(2)(2) of the Danish Criminal Code covers a person who, without authority, by means of a device secretly listens to or records statements made in private, telephone conversations or other conversations between others, or discussions at a closed meeting in which that person does not themselves participate, or to which that person has unlawfully obtained access.

The Danish Data Protection Agency's guidance on audio in connection with CCTV surveillance similarly emphasises that the Danish Criminal Code prohibits secret listening to or recording of conversations between others, and that audio recording will normally be prohibited unless at least one participant in the conversation being recorded has consented to the recording.

In the explanatory notes to Bill L 100 (2024-25), the Danish Ministry of Justice stated that, in the Ministry's view, audio recording, for example in shops, is not covered by the prohibition on secret recording where the recording is carried out openly, for example through clear signage. This statement is included as an interpretative contribution to the assessment. The current statutory wording continues to use the term "secretly".

B.3 Who initiates and carries out the recording

The specific recording is chosen in advance and initiated by the match organiser, who participates in the match. The organiser must inform the other players and confirm they have been made aware before starting. Padel Platform provides and operates the technical infrastructure which records, processes and stores the video and audio. This operational confirmation is not GDPR consent under Article 6(1)(a).

Padel Platform does not assume that the company is, for that reason alone, outside the scope of section 263. The system is therefore designed with technical and organisational limitations intended to reduce the risk of recording unrelated conversations.

B.4 Communication between players on the court

For ordinary use, a significant factor weighing against the application of section 263(2)(2) is that the player who initiates the recording participates in the match and in the communication being recorded. According to its wording, the provision is directed, among other things, at conversations between others in which the person concerned does not themselves participate.

B.5 Unintentional audio from persons outside the court

The principal residual criminal-law uncertainty concerns situations where the microphone unintentionally captures a separate conversation between persons outside the court in which the initiating player does not participate.

Padel Platform does not intend to record such conversations. The microphone is directed at the court, recording is active only during a specific match, and there is no continuous audio recording of the centre. The microphone's actual recording range should be tested and documented and its direction/sensitivity should, where technically possible, be limited to the level necessary for the intended function.

B.6 Open recording and signage

As the solution does not have a separate active REC indicator, clear signage is a central transparency and risk-mitigation measure. The signage must be positioned and designed so that persons on and in the immediate vicinity of the court can genuinely become aware that both video and audio may be recorded.

The information provided must clearly state that video and audio recording is not automatic: the match organiser must actively select the recording option before the match, and the camera and microphone are activated only when that selected recording starts with the match. Signage must also explain that the microphone may capture sounds and conversations from persons nearby and that recording stops when the match ends.

B.7 Wording used on the sign

VIDEO AND AUDIO RECORDING

VIDEO AND AUDIO MAY BE RECORDED ON THIS COURT. Recording is not automatic. If the match organiser actively selects recording before the match, the camera and microphone are activated when that match starts. The microphone is directed at the court but may also capture sounds from nearby persons. Recording stops when the match ends.

The camera records only the court itself. The microphone is directed at the court, but may also capture sounds and conversations from persons nearby.

Recording stops when the match ends.

B.8 Overall section 263 assessment

Padel Platform's primary purpose in using the microphone is to record the audiovisual experience of the specific padel match and not to record conversations between persons outside the court. The specific recording is initiated by a player who participates in the match, and the system is technically limited to the duration of the match and, as far as possible, to the specific court.

In relation to communication between the players on the court, there are significant factors weighing against the intended recording falling within section 263(2)(2). The principal residual uncertainty is the unintentional recording of separate conversations between third parties outside the court. The risk is reduced through clear signage, match-based activation, directing the microphone towards the court, restricted access and practical testing of the microphone's recording range.

Padel Platform therefore does not conclude that every possible audio recording necessarily falls outside section 263. The assessment is that the design and measures described provide significant arguments against the intended recording constituting secret recording of conversations between others, while a residual legal uncertainty remains in relation to the unintentional recording of separate conversations between third parties.

B.9 Legal sources

Danish Criminal Code, section 263(2)(2) - Retsinformation, Consolidated Act No. 434 of 25 April 2024.

Danish Data Protection Agency, guidance on CCTV surveillance for private companies, section on audio recording.

Bill L 100, 2024-25, explanatory notes concerning section 263 and open/secret audio recording, including clear signage.

https://www.retsinformation.dk/eli/lta/2024/434

https://www.datatilsynet.dk/regler-og-vejledning/ofte-stillede-spoergsmaal

https://www.retsinformation.dk/eli/ft/202412L00100/pdf

Document status: Final internal LIA, version 4.1. To be reviewed in the event of material product, processing or legal changes.

Appendix C – Children under 15: private recording permitted; livestreaming prohibited

Policy and assessment update – 3 November 2026. This appendix forms part of the LIA and supersedes any earlier child-specific appendix requiring parental approval for ordinary private recording or allowing livestreaming with parental approval. The assessment is subject to implementation and review conditions below; this document is not a certification of technical controls already deployed.

C.1 Legal basis and the 15-year threshold

The 15-year threshold under Danish GDPR implementation concerns a child’s consent for an information society service offered directly to the child where Article 6(1)(a) is the basis. It is not a universal age below which filming is prohibited or parental consent automatically required. Padel Platform’s intended basis for ordinary private match video/audio is legitimate interests under Article 6(1)(f), requiring a distinct case-specific three-stage test, with particular weight given to children’s rights and reasonable expectations. This legal basis does not displace separate audio-recording obligations or other applicable law.

C.2 Ordinary match recording and highlights involving children

  • Recording is selected before a specific match, not continuous; the fixed camera targets the court, and access is private by default rather than public. Video cannot be switched on retrospectively when a match is claimed.

  • Highlights and recorded match data are provided through the platform’s match-claim/account access flow. Claiming does not create an entitlement to livestream previously recorded content. Access controls and the identity/age verification measures actually in use must be documented and tested.

  • Integrated audio is more intrusive than video; external conversations may be captured. Clearly explain that audio can be present, limit capture practically, and retain the separate section 263 analysis in Appendix B.

  • For children, risks include identifiability of faces/voices, possible embarrassment, recording by another player, downstream sharing, unauthorised access, and the maximum retention of two years. Private-by-default access and an inability to livestream under-15 matches materially reduce, but do not eliminate, those risks.

  • Assess the necessity and proportionality of retaining children’s full-match video and each highlight for up to two years. Two years remains the proposed maximum, not a mandatory retention period. Document why a shorter child-specific period is not sufficient and ensure earlier deletion and objection handling work in practice.

C.3 Absolute livestreaming prohibition for matches involving under-15s

  • No livestream may be activated if one or more players are under 15 years of age, irrespective of parental agreement, the match organiser’s wishes, or whether the video would otherwise be private.

  • The organiser must actively answer before activation whether any player is under 15. If yes, no answer, unknown or inconsistent information, the system must default to no livestream.

  • For adult-only matches, livestreaming requires an explicit pre-match choice and the necessary player information and applicable lawful basis; sharing occurs through an HTTPS link that could be forwarded beyond intended recipients.

  • Livestreaming cannot be added after a match has started or after a recorded match has been claimed. This rule must be enforced at application, API, scoreboard/Point PODS and administration interfaces.

  • An organiser’s declaration is a proportionate basic control but not reliable proof of all other players’ ages. Record the declaration and event timestamp, test bypass vectors, and consider additional checks proportionate to the risks.

C.4 Recording notice, objections and access

The match organiser must inform the other players that private video and audio recording is planned and confirm that they have been made aware. This confirmation is an operational safeguard and must not be described as GDPR consent if the legal basis is Article 6(1)(f). Players have a right to object, requiring a genuine case-specific response by Padel Platform as controller. Where a participant objects before starting, recording should not be activated pending resolution. After starting, the current FAQ states recording cannot be stopped mid-match; Padel Platform should document a practical escalation process, prompt restriction of access where appropriate, and deletion/objection review, and consider a stop control. The creator can delete recordings through their account; other data subjects may request erasure via privacy@padelplatform.app.

C.5 Documentation, safeguards and launch gates

  • Update the public Privacy Policy and the FAQ together, especially references to children, the 15-year threshold, streams, audio, sharing, erasure and retention.

  • Verify and record that under-15 and unknown-age livestream blocking works in each initiation pathway and cannot be bypassed.

  • Validate actual claim/authentication permissions, retention automation, admin logs, the visibility of the age question, and whether mixed-age or anonymous participants are adequately addressed.

  • Carry out and record a child-specific balancing analysis for private audio/video, plus a documented DPIA screening under Article 35; conduct a DPIA if screening identifies likely high risk.

  • Confirm legal assessment of audio recording, including risks of capturing third-party conversations and adequacy of signage.

  • Keep evidence of decisions, actual deployed safeguards, incident handling and periodic review, including the children-specific retention justification.

C.6 Residual risks and decision

The proposed approach can be assessed under legitimate interests for private recording, but its permissibility depends on the child-specific necessity/balancing analysis, implemented protections and actual operation. Unknown or falsely declared ages remain a residual risk. Streaming involving under-15 players is not a permitted processing scenario. Until safeguard verification and DPIA screening have been completed, this text is a documented proposed operational rule, not a statement that all technical checks have been verified.

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