§6.5.1 Testing and adaptation of the design and functioning of recommender systems for minors

65. Providers of online platforms accessible to minors that use recommender systems in the provision of their service should: (a) Regularly test and adapt their recommender systems to enhance the privacy, safety and security of minors and in accordance with the risk review provided under Section 5, which includes a consideration of children’s broader rights. Such testing and adaptation should be conducted by consulting minors, guardians and independent experts. (b) Take into account specific needs, characteristics, disabilities and additional accessibility needs of minors, also with due consideration to their age group, when defining the objectives, parameters and evaluation strategies of recommender systems. Parameters and metrics related to accuracy, diversity, inclusivity and fairness should be prioritised. (c) Ensure that recommender systems do not rely on the collection of any behavioural data that captures the minor's activities off the platform. (d) Ensure that, if a recommender system relies on the processing of behavioural data about a minor, the suggestions of specific information to minor recipients of the service or the prioritisation of that information does not rely on the processing of behavioural personal data that is so extensive as to capture all or most of the minor’s activities on the platform, which may give rise to the feeling that the minor's private life is being continuously monitored. (e) Ensure that recommender systems rely on ‘implicit engagement-based signals’ only after having assessed whether it is in the best interests of the minor, taking into account the principles of data minimisation and transparency, and provided that such use is clearly defined and subject to appropriate safeguards as further defined in the recommendations above. (f) For the purposes of the present guidelines, ‘implicit engagement-based signals’ shall be understood as referring to signals and data that infer user preferences from their activities (browsing behaviour on a platform), such as time spent viewing content and click-through rates. (g) Prioritise ‘explicit user-provided signals’ to determine the content displayed and recommended to minors. The selection of such signals should be justified in the best interests of the minor, taking into account the principles of data minimisation and transparency, which will help to ensure that they contribute to a high level of safety and security for minors. For the purposes of the present guidelines, ‘explicit user-provided signals’ shall be understood as referring to user feedback and interactions that indicate users’ explicit preferences, both positive and negative, including the stated and deliberative selection of topics of interest, surveys, reporting (65), and other quality-based signals. (h) Implement measures to prevent minors’ exposure to content recommendations that could pose a risk to their safety and security, particularly when encountered repeatedly, such as content promoting unrealistic beauty standards or dieting, content that glorifies or trivialises mental health issues, such as anxiety or depression, discriminatory content, radicalisation content and distressing content depicting violence or encouraging minors to engage in dangerous activities. This includes content that has been reported or flagged by users, trusted flaggers or other actors or content moderation tools, and whose lawfulness and adherence to the platform’s terms and conditions have not yet been verified, in accordance with the relevant obligations under Regulation (EU) 2022/2065 and with Section 6.7. (i) Implement measures to ensure that recommender systems do not enable or facilitate the dissemination of illegal content or the commitment of criminal offences against and by minors. (j) Ensure that minors’ search results and suggestions for contacts prioritise accounts whose identity has been verified and contacts are connected to the network of the minor, or contacts in the same age range as the minor. (k) Ensure that search features, including but not limited to text autocomplete on the search bar and suggested terms and key phrases, do not recommend content that is illegal and/or qualifies as harmful to the privacy, safety or security of minors, for instance by blocking search terms that are well-known to trigger content that is deemed to be harmful to minors’ privacy, safety and/or security, such as particular words, slang, hashtags or emojis (66). Upon queries related to such content, providers of online platforms should redirect minors to appropriate support resources and helplines.

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Source: EUR-Lex (Cellar) · retrieved 2026-09-07